2007 Ozone Plan 

Chapter 7 

 

Action Plan for Reducing Emissions 

with Incentive Funds 
2007 Ozone Plan 

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Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Chapter 7: Action Plan for Reducing Emissions with 

Incentive Funds

Chapter 7 is an action plan in progress, and it includes the best estimates of 

possible emissions reductions that can be achieved from potential, future 

funding. At this point, the District is not taking SIP credit for programs described 

in Sections 7.6 and 7.7 since they depend on funding that has not yet been 

secured. The action plan outlined in this chapter reflects the District’s attempt in 

formulating a plan to achieve maximum reductions in the shortest time possible. 

As we proceed with the legislative process and achieve expected advancements 

in pollution control technologies, the District will revise this action plan to ensure 

optimal use of public funds in future revision. 

7.1 INTRODUCTION 

With this plan, mobile sources and stationary sources will become subject to new and 

more stringent regulatory requirements. However, even with an aggressive regulatory 

component as proposed in this plan, regulations alone cannot bring about all the 

reductions that are necessary to reach attainment. Stationary sources are already 

heavily controlled, and more stringent tail-pipe standards for new vehicles will not 

produce reductions until the old engines are replaced with cleaner new engines. With 

incentives, the full benefit of the new engine standards will be accelerated by several 

years. Incentive grants can also allow for adoption of cleaner technologies that may 

otherwise be unaffordable. 

As this plan is implemented, over 50% of the San Joaquin Valley’s population will see 

attainment of the 8-hour ozone standard in 2015, with over 90% reaching attainment in 

2020. Without the incentive funds called for in this plan, these figures will be reduced to 

35% in 2015 and 65% in 2020. Therefore, without the incentive measures proposed in 

this plan, attainment of the ozone standard will be delayed to after 2020 for over 

1,000,000 Valley residents. Furthermore, without the proposed incentives, the San 

Joaquin Valley may not reach attainment of the PM2.5 federal standard by 2015 as 

currently mandated by the federal Clean Air Act. 

Through incentives, funding is provided for projects that achieve emission reductions to 

supplement those from rules and regulations. Incentives allow the District to reduce 

emissions from source categories outside of the District’s regulatory authority, as well 

as source categories where financial hardship would otherwise prevent traditional 

control strategies from being implemented. Since its inception, the District has awarded 

over $135 million in matching funds to projects that have resulted in over 52,000 tons of 

lifetime emission reductions at an average cost-effectiveness of approximately 

$2,600/ton. 
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The amount of funding currently available to the District for incentive-based programs is 

approximately $40 million per year. The primary sources for these funds are the 

expected revenues from the District’s Indirect Source Review Rule, voluntary 

development mitigation agreements, local DMV surcharge fees, and the state’s Carl 

Moyer Program. This plan calls for a significant increase in incentives to bring a large 

segment of the San Joaquin Valley population into attainment earlier than otherwise 

possible and to allow for the application of advanced technologies that will be required 

for bringing the entire San Joaquin Valley into attainment. To reach this goal, the San 

Joaquin Valley will need an average of $188 million in incentive funding annually until 

attainment is reached. 

For the San Joaquin Valley to be successful in securing the necessary incentive 

funding, an advocacy effort with the public sector, business community, environmental 

community, and the general public, all requesting resources, will be necessary. The 

District, as well as a number of stakeholders, has begun an advocacy effort at the state 

and federal levels through a multi-pronged approach. The District is requesting $100 

million per year in federal funding with the remainder coming from state and local 

sources. 

This chapter provides a detailed action plan for securing and expending the proposed 

incentive funds. It is important to point out that, in this plan, we cannot legally take 

credit for potential reductions from incentive measures until binding commitments (e.g., 

state and/or federal legislation) securing the proposed funding levels are in place. 

However, to ensure State Implementation Plan (SIP) creditability once the funding is 

secured, the District in consultation with the federal EPA, has established the framework 

for enforcement and accountability. Please refer to section 7.5 for further details on SIP 

creditability. 

7.2 DISTRICT EXPERIENCE TO DATE IN ADMINISTERING AND IMPLEMENTING 

INCENTIVE PROGRAMS 

The District has significant experience in operating successful incentive programs since 

1992. The programs have expanded in funding and increased in sophistication over the 

years. The District is currently operating two incentive programs aimed at reducing 

precursor emissions: the Heavy-Duty Engine Emission Reduction Incentive Program 

(Heavy-Duty Engine Program) and the Reduce Motor Vehicle Emissions II (REMOVE II) 

Program. As opportunities to achieve cost-effective emission reductions present 

themselves and funding becomes available, the District has been willing to develop new 

programs and new components for existing programs. 

Since 1992, the District has awarded over $135 million to projects that have resulted in 

over 52,000 tons of lifetime emission reductions at a cost-effectiveness of approximately 

$2,600/ton. In 2006, the District executed 461 agreements through the incentive 

programs for a total of $31.1 million. The types of projects funded include diesel 

agricultural irrigation pump replacements, on-road and off-road vehicle engine 
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replacements, new vehicle purchases, locomotive replacements, vanpools, bicycle path 

construction and transit pass subsidies. Over the project life, these projects are 

expected to reduce 8,118 tons of NOx, PM, and VOC. 

In developing new incentive programs, District begins by securing funding. Then, in 

consultation with the California Air Resources Board (ARB) and federal Environmental 

Protection Agency (EPA), the District develops a proposed framework for the policies 

and procedures for program administration. These procedures are designed to ensure 

efficient program administration; applicant and District accountability; and adequate 

enforcement authority. Typically, new incentive policies and procedures are based on 

existing ARB guidance documents, such as the Carl Moyer Program Guidelines. The 

District then presents the proposed framework to the public for comments. Upon 

receiving comments, District staff refines the framework as appropriate and develops a 

policies and procedures document for program administration. This document is 

presented at a public meeting where the ARB, EPA, and public have an opportunity to 

comment. Finally, the document is presented to the District's Governing Board for 

approval. Upon approval by the District's Governing Board, the new program is 

implemented in accordance with the approved policies and procedures document. 

7.2.1 Heavy-Duty Engine Emission Reduction Incentive Program 

The Heavy-Duty Engine Program is by far the District's largest and most successful 

incentive program. The Heavy-Duty Engine Program accepts applications for a wide 

variety of engines that power vehicles or equipment. It provides funding for new 

purchases (differential cost only, in most cases), engine repowers, or retrofits. Emission 

reductions are obtained when the project applicant purchases vehicles and engines that 

are cleaner than required by current emission standards or installs emission 

certified/verified retrofit kits on existing engines. The District pays a portion of the 

differential cost of purchasing the lower emitting technology compared to conventional 

technology up to a cost-effectiveness cap of $14,300 per combined tons of NOx, PM 

and VOC. 

The first projects that were funded began operating in 1998. Since then, each year 

additional funds have been allocated to the program and additional projects have 

become operational. Project life varies from 3 to 20 years depending on the application, 

with an average project life of 5 years based on the mix of projects received to date. 

Emission reductions are cumulative since additional projects are completed each year. 

The 2003 PM10 Plan projected emission reductions utilizing currently available funding 

would amount to 6.3 tons per day of NOx by 2005. The 2003 PM10 Plan also indicated 

that the District expected additional funding would be obtained to allow continued 

emission reductions in later years. 

The most successful component of the program is the replacement of agricultural 

irrigation pump engines used for water pumping. Approximately 65% of all engines 

repowered have been uncontrolled diesel agricultural irrigation pump engines that have 
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been replaced with new engines meeting current off-road engine standards or electric 

motors. 

Principal components of the Heavy-Duty Engine Program are the Agricultural Irrigation 

Pump Engine Component, On-Road Vehicle Component, Off-Road Vehicle Component, 

Locomotive Component, Marine Vessel Component, Forklift Component, Airport 

Ground Support equipment, Idle Reduction Component, and Alternative Fuel 

Infrastructure Component. 

7.2.2 REMOVE II Program 

The Reduce Motor Vehicle Emissions (REMOVE) Program was the District's first 

incentive program. It began its first phase in 1992. The District has developed a new, 

enhanced program (REMOVE II) that was approved by the Governing Board in 

February 2005. REMOVE II reduces emissions from light- and medium-duty motor 

vehicles in the District. The purpose of this grant program is to assist the District in 

attaining air quality standards. This is accomplished by allocating funds to cost-effective 

projects that have the greatest motor vehicle emission reductions, thereby creating 

long-term air quality benefits for the San Joaquin Valley. All projects must have a direct 

air quality benefit to the District. Any portion of a project that does not directly benefit 

the District within its boundaries is not allowed for funding or in calculating emission 

reductions. 

Principal components of the REMOVE II Program are the Light- and Medium-Duty 

Vehicle Component, the E-Mobility (Telecommunications) Component, the Bicycle 

Infrastructure Component, the Public Transportation and Commuter Vanpool Subsidy 

Component, Accelerated Vehicle Retirement Component and the Alternative Fuel 

Vehicle Mechanic Training Component. 

7.2.3 Light and Medium-Duty Vehicle Incentive Program 

In 2002, the District completed a highly successful Light and Medium-Duty Vehicle 

Incentive Program. The program provided incentives for the purchase of low-emission 

passenger vehicles, light trucks, small buses, and trucks less than 14,000 pounds gross 

vehicle weight. The purpose of the program was to encourage the early introduction of 

low-emission vehicles in the District. The program paid between $1,000 and $3,000 per 

vehicle depending on the emission certification level and size of the vehicle. Vehicles 

were required to be powered by alternative fuel, electricity, or hybrid electric 

engines/motors. Emission reductions from vehicles purchased under this program were 

claimed under ARB's Low Emission Vehicle program. These types of vehicle projects 

are now funded through the REMOVE II Program. 
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7.2.4 Electric Lawnmower Incentives 

For the last several years, the District has operated an electric lawnmower exchange 

incentive program known as the Clean Green Yard Machine Program. The District 

worked with electric lawnmower manufacturers and local equipment dealers to provide 

large discounts to people who turned in their gasoline-powered mowers in exchange for 

electric or push-type lawn mowers. For 2004, District funding provided discount 

coupons for electric and push-type lawn mowers and 327 mowers were sold in 2004 

under the coupon program. In 2005, the District sold 595 electric lawn mowers to 

District residents who traded-in their old gas-powered mowers. In 2006, the District 

increased the program and sold 798 electric mowers over the course of five events. 

This is an example of a new program that will likely be continued in coming years if 

funding is available. 

7.3 EXISTING FUNDING SOURCES IN THE SAN JOAQUIN VALLEY 

Current programs use a combination of state and local funds, including ARB's Carl 

Moyer Program, the District’s Department of Motor Vehicles Surcharge Fees (DMV 

Fees), Indirect Source Review (ISR) fees and Voluntary Developer Mitigation Contract 

(DMC) fees, as shown in Table 7-1. The District has achieved significant, cost-effective 

emission reductions from a variety of grant programs and will seek funding for costeffective programs from all potential sources. Emission reductions claimed for this plan 

are based on funding already committed, as shown in the table below. The mix of 

locally generated funding, state funding, and federal funding will vary. 

7-1 Existing Funding Sources 

Source Estimated Annual Available Funding* 

DMV Surcharge 

Fees $11 Million 

Moyer Funds $9.5 Million 

ISR/DMC Funds $19.5 Million 

Total $40 Million 

* The total available funding can potentially be reduced by approximately $15 million per year 

beginning in 2016 unless reauthorizations are granted for the Moyer Program and $2 DMV 

Surcharge Fee (AB 923) funds. 
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Calculating the reductions expected from incentive programs involves several steps and 

assumptions. First, although the project life for each project is expected to be ten years, 

the District conservatively calculates reductions for the first three years of the project 

under the assumption that if the equipment hadn’t been replaced under the grant, then 

after three years, the old equipment would have been replaced under natural fleet 

turnover. Therefore, grant funds awarded in 2007 are expected to achieve surplus 

reductions in 2007, 2008, and 2009. Also, to calculate the total reductions being 

achieved by incentive programs in 2009, for example, the reductions from funds 

distributed in 2009, 2008, and 2007 are considered. Second, the cost effectiveness 

(cost per ton of reductions) for District incentive programs in 2007 is $14,000 per ton. 

The cost per ton increases over time due to inflation, so the District assumes a 6% 

increase in cost effectiveness each year. Third, the total secured incentive funding 

decreases with the expiration of Moyer and part of the total DMV fees in 2015, unless 

these programs are re-authorized by the California Legislature. The total NOx 

reductions achieved by incentive programs with secured funding in key years are shown 

in Table 7-2. 

Table 7-2 NOx Reductions Achieved by District Incentive 

Measures with Assured Funding 1 

1

 Reductions achieved with Moyer incentives are not included in the 

reductions listed here since ARB takes credit for these reductions in 

Table B-2. 

7.3.1 DMV Surcharge Fees 

State law provides air districts that are designated as state non-attainment for a 

pollutant emitted by motor vehicles to receive revenues from motor vehicle surcharge 

fees collected and disbursed by the State Department of Motor Vehicles. Legislation 

(AB 2766) was enacted in 1990 to enable air districts to receive up to a $4 surcharge 

per vehicle on motor vehicle registration fees. These fees provide air districts with 

funds to meet their responsibilities mandated under the California Clean Air Act (CCAA) 

without raising fees on stationary sources. The California Health and Safety Code 

states that these motor vehicle surcharge fees shall be used to support air districtoperated planning, monitoring, enforcement, and technical studies necessary to 

implement the CCAA, including incentive programs that reduce motor vehicle 

emissions. 

Additional legislation (SB 709) was enacted in 2003 allowing the District to receive an 

additional $1 surcharge per motor vehicle. The funds generated by this surcharge may 

only be used to reduce emissions from vehicular sources, including, but not limited to 

the establishment of a clean fuels program and the adoption and implementation of 

Year NOx reductions 

(tpd) 

2012 1.4 

2020 0.7 

2023 0.6 
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motor vehicle use reduction measures. The District may utilize up to 2 percent of the 

funds received for administrative expenses. 

In 2004, air districts were allowed to adopt an additional $2 motor vehicle surcharge fee 

(AB 923). The funds generated by this additional surcharge may be used only to 

reduce emissions from certain motor vehicle and agriculture sources, including Carl 

Moyer Program projects, and for the new purchase, retrofit, repower, or add-on 

equipment for previously unregulated agricultural sources, school buses, and an 

accelerated vehicle retirement or repair program. The District may utilize up to 5 

percent of the funds received for incentive program administrative expenses. This 

additional surcharge will remain in effect only until January 1, 2015, unless reauthorized by the California Legislature. 

It is estimated that approximately $11 million per year will be available for incentive 

grants from District DMV fees. 

7.3.2 Carl Moyer Memorial Air Quality Standards Attainment Program 

The Carl Moyer Memorial Air Quality Standards Attainment Program (Moyer Program) 

is a grant program, implemented by a partnership of the ARB and local air districts, 

which funds the incremental cost of cleaner-than-required engines, equipment, and 

other sources of pollution. Eligible project types include on-road heavy-duty vehicles, 

idle reduction technologies, off-road diesel equipment, transportation refrigeration units, 

off-road spark-ignited equipment, marine vessels, locomotives, and agricultural engines. 

Legislative changes enacted in 2004 provide increased and continued funding for the 

Moyer Program through 2015, unless re-authorized by the California Legislature. 

It is estimated that approximately $9.5 million per year will be available to the District for 

incentive grants from Moyer Program funds. 

7.3.3 Indirect Source Review and Voluntary Developer Mitigation Contract Funds 

The District’s ISR Rule was developed to achieve a number of goals, including the 

reduction of NOx and PM emissions from new development projects. The rule requires 

a certain amount of emission reductions from each development project, which can be 

achieved by utilizing one of several approaches. Paying a fee to fund projects that will 

reduce emissions off-site is an option for rule compliance. Funds from this option will be 

used for NOx and PM emission reduction projects through the District’s incentive 

programs. Additionally, funds are also derived from developer mitigation contracts in 

which certain developers choose to mitigate 100% of the emissions from their 

development projects. These fees are then used to fund emission reduction projects 

through the District’s incentive programs. 

For the purpose of this analysis, it is estimated that approximately $19.5 million per year 

will be available for incentive grants from ISR and DMC fees. 
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7.4 POTENTIAL SOURCES FOR ADDITIONAL STATE AND FEDERAL FUNDING 

Current state and local funds available to the San Joaquin Valley for incentive-based 

programs in the District are approximately $40 million per year. The primary sources for 

these funds are the expected revenues from the District’s Indirect Source Review rule, 

voluntary development mitigation agreements, local DMV surcharge fees, and the 

state’s Carl Moyer program. Additionally, the San Joaquin Valley receives funding that 

can be utilized for air quality projects that is allocated by agencies other than the 

District. 

The federal transportation funding program provides Congestion Mitigation and Air 

Quality (CMAQ) funds to non-attainment areas to fund transportation projects that 

improve air quality. These funds are allocated by the eight county level Metropolitan 

Planning Organizations (MPOs) in the Valley. While the draft guidance for the 

allocation of CMAQ funding provides a renewed focus on cost-effective emissions 

reduction projects, transportation agencies often weigh other criteria, such as 

congestion relief, when allocating CMAQ funds. 

The federal farm bill provides air quality funding through the Environmental Quality 

Incentives Program (EQIP). EQIP funds are distributed by the Natural Resource 

Conservation Service (NRCS). San Joaquin Valley agriculture receives approximately 

$5.5 million per year in EQIP funding. These funds can be utilized for dust control 

activities and to reduce emissions from agricultural engines. Historically, approximately 

$1.15 million per year has been utilized to reduce emissions from agricultural engines; 

however, the program does not require that the funds be utilized for any particular 

category. 

The Environmental Protection Agency (EPA) administers funding from the Diesel 

Emissions Reduction Account (DERA) to fund projects that reduce emissions from 

diesel engines. The DERA program is a national program that has been authorized, but 

never fully funded, at $200 million per year. To date, the San Joaquin Valley has 

received approximately $700,000 in DERA funding. 

7.5 ENHANCING SIP CREDITABILITY OF INCENTIVE BASED EMISSION 

REDUCTIONS 

7.5.1 Introduction 

Air quality management agencies use a number of tools to improve air quality, including 

rules and regulations, alternative compliance, and incentives. Incentive programs use 

contracts with organizations and individuals to provide all or part of the funds needed to 

carry out projects that reduce air pollutant emissions and improve air quality. These 

projects usually involve sources outside agencies’ regulatory authority and are focused 

on reductions above and beyond those required by rule or regulation. Current federal 
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policy limits the use of incentive-based reductions emission reductions to meet FCAA 

goals in air quality plans. Because the District will depend heavily on incentive-based 

reductions to meet FCAA requirements in future air quality plans, the District is working 

with the EPA to identify ways to ensure that emission reductions from incentive 

programs can be used in air quality plans (State Implementation Plans or SIPs) to meet 

FCAA requirements. When EPA approves the use of incentive-based reductions in air 

quality plans (alongside reductions from traditional rules and regulations), the reductions 

are said to be “SIP creditable.” However, the use of incentive-based reductions is 

limited to known existing funding sources under the fiduciary control of the applying 

agency. 

SIP creditable emission reductions from incentives are essential to the District’s future 

SIPs for a number of reasons, including: they are needed for future plans to meet clean 

air goals; they historically have been a very cost-effective approach to reduce air 

pollutant emissions; and they will continue to help generate a demand for future 

incentive projects that in turn will help insure adequate future sources of incentive 

funding (in other words, people will want to implement incentive projects if they know 

that the reductions from the projects will improve air quality and help meet FCAA 

requirements). 

7.5.2 Background 

As noted in Chapter 1, air quality in the San Joaquin Valley has improved tremendously 

in recent years, largely due to the effectiveness of the rules and regulations adopted by 

the District, supplemented by reductions from state and federal rules and regulations. 

Recent examples of these improvements include a finding from the EPA that the San 

Joaquin Valley is in attainment of the National Ambient Air Quality Standards 

(NAAAQS) for PM10 and a dramatic reduction in the number of days exceeding the 1-

hour ozone NAAQS from 1990 to 2005. The District’s rules and regulations have 

reduced NOx and VOC emissions from permitted stationary sources by over 50%. 

Despite this progress, however, the District still doesn’t meet health-based standards for 

two newly implemented NAAQS: 8-hour ozone and PM2.5. 

In developing the 8-hour ozone plan, the District is examining current rules and 

regulations, and exploring new rules and regulations to identify new emission reductions 

needed to attain the 8-hour ozone NAAQS and meet other requirements of the FCAA. 

Because emissions from District-regulated sources are already greatly reduced due to 

prior successful air pollution control rules and regulations implemented by the District, 

and because the District only has authority to control a fraction of the emissions causing 

the 8-hour ozone problem, a limited amount of emission reductions will be available 

from additional rules and regulations on sources under District control for the 8-hour 

ozone (and PM2.5) plans. Consequently, the District must turn to emission reduction 

mechanisms that allow it to affect sources traditionally outside of its regulatory control or 

that lack the financial wherewithal to reduce emissions. One such mechanism is 

incentive programs. Emission reductions from incentive programs, in order to be used 

in SIPs, must meet the following EPA criteria: (a) they must be surplus to reductions 
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required by regulations, (b) they must be quantifiable, (c) they must be enforceable, and 

(d) they must be permanent for the life of the emission reduction project. 

As discussed in Section 7.2, the District has a long and successful history of achieving 

emissions reductions through incentive programs, and has taken some credit in SIPs for 

a limited portion of those reductions. The increased importance of incentives in the 

Valley’s emission reduction strategy for meeting FCAA requirements for 8-hour ozone 

means that the District will need to change certain aspects of how it operates its 

incentive program in order to be able to maximize the incentive-based emission 

reductions used to meet federal requirements in SIPs. The District has been working 

with EPA Region IX since July of 2006 to develop changes to the incentive program that 

will ensure that all reductions achieved under these program changes will be creditable 

in SIPs. In August 2006 the District released a Draft Staff Report outlining proposed 

changes to the incentive program in order to ensure SIP creditability for incentive-based 

emission reductions. The District plans to use the public comments received during this 

process to develop the incentive program changes as a separate Governing Board item 

later in 2007. 

The remainder of this section describes mechanisms that will enhance the SIP 

creditability of emission reductions generated by the District’s incentive programs. SIP 

creditable incentive-based emission reductions can be used alongside rule-based 

emission reductions to meet FCAA requirements such as demonstrating attainment with 

the NAAQS at a future date or demonstrating that emission reductions meet reasonable 

further progress requirements. The mechanisms consist of Protocols, Contracts, and a 

Tracking/Reporting System. The following sections describe specific commitments that 

the District will meet for incentive-based reductions that are used to meet federal Clean 

Air Act requirements. See Appendix Q for a sample resolution with these commitments. 

7.5.3 Proposed Changes to Incentive Program Operation 

The District’s incentive programs already have many elements that contribute to the 

creditability of emission reductions from the program in SIPs. The changes that are 

being proposed to enhance the SIP creditability generally deal with increased postproject monitoring, verification of emission reductions and comparison with predicted 

reductions, real-time reporting of emission reductions with associated preparation of 

annual reports, and development of program elements such as protocols in a 

transparent and open process. Specific changes to elements of the District’s incentive 

program are described below. 

1. Protocols 

Since 1992, the District has developed and refined specific protocols and 

procedures for the incentive programs, including procedures for contracting, 

auditing and enforcement of emission reduction projects. Protocols are the 

detailed processes that District staff use to calculate emission reductions from 

incentive-funded air pollution control projects. These protocols have been 
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developed in accordance with all regulatory requirements governing the specific 

sources of funds used in the incentive programs (e.g., the Carl Moyer Program). 

See Appendix Q for links to ARB websites that describe established protocols 

and for examples of the types of calculations used in protocols. 

Under the proposed changes to the District’s incentive programs, District staff will 

develop new protocols in an open public process that will provide opportunity for 

public comment, and these protocols will help ensure that the reductions are SIP 

creditable. This open public process will include the issuance of a draft protocol, 

holding at least one workshop on the draft protocol, revising the protocol as 

needed based on public comment, and adopting the protocol at a duly noticed 

public hearing of the District Governing Board. 

Projects that are being funded with Moyer Program funds will be evaluated 

according to the existing Moyer Program Guidelines. Emission reductions 

stemming from incentive contracts awarded in accordance with the Moyer 

Program Guidelines generally meet the SIP creditability criteria, and no new 

District protocols will be established for Moyer Program projects. At its discretion 

the District will use Moyer Program Guidelines to calculate creditable emission 

reductions for incentive projects funded by other than Moyer Program incentive 

funds. However, District protocols are needed for other funding sources 

including DMV surcharge fees, Indirect Source Review fees and Developer 

Mitigation Contract funds, unless the District chooses to use Moyer for these. 

By following the protocols, District staff will be able to quantify the applicable 

emission reductions, demonstrate the permanency of the reductions for the life of 

the emission reduction project, and demonstrate that emission reductions from 

particular types of projects or source categories are surplus (including a 

description of the process used to determine reductions are surplus). 

The proposed changes to District incentive program operation will include 

protocol development according to the following process: 

a. District staff will develop a draft protocol that will be published for stakeholder 

and ARB comment. 

b. District staff will transmit each draft protocol to EPA Region IX staff for review 

and comment. 

c. District staff will summarize and address ARB, EPA and public comments. 

The comments and responses will be a part of the Governing Board package 

for the proposed protocol submitted to the Board for consideration for 

adoption. District staff will not present a draft protocol for approval if EPA 

expresses objections to the protocol. 

The District will update any board-adopted protocol on a regular basis to take into 

account new SIP provisions, new emission standards and new emission factors 
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in order to ensure surplus reductions and to improve the accuracy of the 

quantified reductions. 

2. Contracts, Audits & Enforcement 

The District has developed contract templates for a variety of emission reduction 

project types. Each contract template includes a detailed description of the 

project, specific obligations of the District and the participant including auditing 

procedures, non-compliance penalties, actions that the grantee must take to 

achieve the reductions, reporting and record keeping. 

District staff has developed procedures for the administration of the incentive 

programs to ensure that the reductions from the projects are quantifiable, 

surplus, permanent for the life of the project, and enforceable. 

Currently, the District verifies that a given funded incentive-based emission 

reduction project is operational, but does not routinely conduct post-operational 

inspections to verify that the operational parameters used to calculate the 

anticipated reductions are being realized for the project. 

Under the proposed changes to incentive program operations, the District would 

conduct periodic inspections of all funded incentive-based emission reduction 

projects, and use the information gathered in conjunction with the annual report 

that the District requires from each applicant to make sure that operational 

parameters used to calculate incentive-based emission reductions used in one or 

more SIPs are being achieved. 

It is important to note that many of the units that will be receiving incentive 

funding from the District may be permitted or registered through the District, and 

as such, will be included in the District’s inspection and monitoring program. 

 

When non-compliance is documented, notices of violation (NOVs) or notices to 

comply (NTCs) are issued, per District policy. The District has an existing 

enforcement program, including an established mutual settlement program that 

levies fines for NOVs based on the nature, magnitude, and reoccurring nature of 

infractions. Non-compliance issues that cannot be resolved through the mutual 

settlement program will be transferred to the District’s Legal Department for final 

disposition. 

For projects that do not fall under a District permit or registration requirement, the 

protocols that are developed will include source-type-specific monitoring, record 

keeping, and reporting requirements that will ensure that the anticipated 

incentive-based reductions are successfully and consistently achieved, with 

much the same approach as taken with registered or permitted equipment. 

Inspections will be conducted, reports will be completed, civil action will be taken 

if needed for non-compliance, and summaries of compliance reports will be 

included with the annual report. 
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The District would investigate any emission reduction shortfalls that are identified 

(i.e., actual emission reductions are less than predicted emission reductions) to 

determine if the shortfall is due to a violation of the terms of the contract on the 

part of the applicant or due to factors outside of the contract. If contractual 

factors are the primary cause, the District will use existing legal avenues to 

correct the problem. If the shortfall is caused by factors outside of the contract, 

then the District will identify the cause and re-compute anticipated emission 

reductions. In either case, the District will meet any emission reduction shortfalls 

remaining after this investigation through mechanisms such as funding more 

emission reduction incentive projects or adopting rules and regulations. 

3. Tracking & Reporting 

The District will develop a Project Tracking System that will allow calculation of 

actual emission reductions based on field data collected during field inspections 

and from the required annual report, as well as from other sources. The system 

would be linked to the District’s web site to achieve real-time reporting of actual 

versus predicted emission reductions from categories of incentive projects, as 

well as a running total of actual versus predicted reductions. 

In addition to the real-time reporting of incentive-based emission reductions, the 

District commits to preparing an annual report on its incentive programs. Major 

elements of the report include the following: 

! Sources of funding 

! Expenditures 

! Types of projects funded 

! Actual versus predicted emission reductions 

! Enforcement activities 

• Number and type of inspections conducted on grantees 

• Number of all grantees for whom there is evidence of noncompliance 

• List of enforcement actions taken by the District and the 

resultant penalties and remedies 

! Description of the permanency of the funding sources and ideas for 

amending the program in the event of reduced funding 

If an annual report indicates a shortfall of emission reductions, the District will revise any 

air quality plan(s) dependent on those reductions to meet requirements and will submit 

an amended plan to EPA within 12 months of the date of the hearing on the annual 

report. This plan amendment will have the changes necessary to assure compliance 

with all applicable FCAA requirements. These changes may include additional 

regulatory measures or enhanced funding to generate the necessary reductions in the 

timeline necessary to meet FCAA requirements. As noted in Chapter 5, the annual 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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report on incentives will be part of a larger District annual report on fulfilling Ozone Plan 

and Particulate Matter Plan commitments. 

7.5.4 Conclusions and Next Steps 

SIP creditability of emission reductions from incentive programs is critically important for 

the District to meet FCAA requirements for 8-hour ozone and PM2.5. Historically, 

incentive-based emission reductions have been a cost-effective way to improve air 

quality in the San Joaquin Valley. 

The District’s incentive programs already contain many elements that contribute to the 

SIP creditability of emission reductions. The changes that are being proposed to 

enhance the SIP creditability of the District’s incentive programs generally deal with 

increased post-project monitoring, verification of emission reductions and comparison 

with predicted reductions, real-time reporting of emission reductions with associated 

preparation of annual reports, and development of program elements such as protocols 

in a transparent and open public process. 
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The following sections are provided for information only and 

are not intended for inclusion in the SIP. 

7.6 DISTRICT ACTION PLAN FOR EXISTING AND FUTURE INCENTIVE FUNDS 

The District operates incentive programs to assist in attaining air quality standards by 

providing financial incentives for the early introduction of new technologies and the 

promotion of alternative transportation measures. Additional significant financial 

resources from the state and federal governments will be needed to achieve the 

necessary emission reductions. Existing funding sources will be allocated to the most 

cost-effective measures in order to maximize the emission reductions per dollar spent. 

For all incentive-based emission reductions used to meet federal Clean Air Act 

requirements, the District will take the actions necessary to ensure that reductions are 

quantifiable, enforceable, and surplus to reductions attributed to the regulatory 

programs contained in the SIP. To assure SIP creditability, disbursement of the funds 

would be based on protocols agreed to between ARB, EPA, and the District. The Carl 

Moyer Program Guidelines will be used as a model for new District Governing Board 

approved protocols for calculating SIP creditable reductions. 

As noted in the previous sections, the District will develop future incentive program 

protocols through a public process. During this process, EPA will have the opportunity 

to review and approve the proposed protocols. The District Governing Board will then 

approve the proposed protocols. 

The District will track actual emission reductions from incentive-based programs on an 

ongoing basis with annual reports to the public, EPA, and the Governing Board. At a 

minimum, the annual reports will describe the amount of public funds spent, verify the 

amount of actual emission reductions versus predicted reductions, discuss any 

quantification or surplus issues that have arisen during the reporting period and how 

they were resolved, and include or reference publicly available electronic information or 

records for each grant issued. 

The District will also ensure that the emission reductions are permanent and 

enforceable through pre and post project inspections and ongoing monitoring and 

record keeping. 

7.6.1 Potential Incentive Measures 

The following potential incentive measures are being recommended for obtaining the 

maximum amount of cost-effective emission reductions utilizing existing and additional 

future state and federal funding sources. The potential incentive measures identify 

potential emission reductions and the costs associated with realizing those reductions. 

Each analysis will contain a detailed discussion of the source category for which an 

Incentive Control Measure is being recommended. These discussions will include 
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information on upcoming regulations, which may impact the availability of surplus 

reductions, possible control techniques, the associated emission inventory for each 

source category, as well as potential emission reductions, possible emission reduction 

strategies and, finally, recommendations. A description of each of the individual 

Incentive Control Measure section headings, and terms in these sections follows: 

Source Category: This section describes in detail the specific targeted sources of 

emissions. Each source category is comprised of a group or groups of similar emission 

sources, such as agricultural internal combustion engines or school buses. 

Upcoming Regulations: This section discusses any upcoming local, state or federal 

regulations, which may impact the availability of surplus reductions or the feasibility of 

certain control techniques for each source category. 

• Surplus Reductions: In general, surplus reductions are the emission reductions 

achieved from the baseline emission rate that exceed the reductions claimed by 

other entities through rules, regulations, permits, and emission reduction credit 

programs. 

Control Techniques: This section describes the specific methods for controlling 

emissions from a particular source category. 

Emission Inventory and Possible Emission Reductions with no Constraints: This 

section describes the total emission inventory, by pollutant, for each source category. 

The emission inventory and associated emission projections was developed jointly by 

ARB and air districts. The analyses contain the latest emission inventory information 

that is currently available. If new information becomes available, the emissions 

inventory section will be updated to reflect these changes. The Potential Emission 

Reduction Assuming No Financial, Technological, or Logistical Constraints tables for 

NOx and VOC show the following: 

• Projected Inventory with no Incentives: The current ARB and District developed 

inventory for the source category, assuming no new incentive programs or 

regulations. 

• No Constraints Inventory: The emission inventory if every imaginable control, 

including those that are not feasible due to financial, technological, or logistical 

constraints, were implemented. 

• No Constraints Reductions: The emission reductions if every imaginable control, 

including those that are not feasible due to financial, technological, or logistical 

constraints, ere implemented. These reductions include surplus and non-surplus 

emission reductions. 
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Possible Strategies (Scenarios): This section describes and discusses a variety of 

strategies to control emissions from a particular source category. These scenarios 

include consideration of financial, technological, and logistical constraints. Generally, 

several strategies or scenarios are presented and discussed in this section. 

Recommendation: This section discusses which of the possible strategies is being 

recommended by District staff based on feasibility, potential emission reductions and 

considering all financial, technological and logistical constraints. 

Recommended Strategy: This table provides details about the strategy or strategies 

that are being recommended by District staff, including: the total project cost, grant 

recipient match, total incentive funds needed, existing available funding and the amount 

of new funding that would be necessary to implement the recommended strategy. Each 

specific line item in this table is defined below: 

• Total Project Cost: This figure represents the total cost to implement the 

recommended strategy (District Funding + Grant Recipient Match) 

• Grant Recipient Match (percent): This figure represents the percentage of 

the total cost of the recommended strategy that would be contributed by the 

grant recipient, or the total out-of-pocket cost. 

• Grant Recipient Match (Cost): This figure represents the total cost of the 

recommended strategy that would be contributed by the grant recipient, or the 

total out-of-pocket cost. 

• Total Incentive Funds Needed (Cost): This figure represents the total project 

cost minus the grant recipient match cost. 

• Existing Available Funding: This figure represents the amount of existing 

grant funding that the District can commit to the total project cost. 

• New Funding Required: This figure represents the current or expected 

funding shortfall after subtracting the Existing Available Funding and Grant 

Recipient Match from the Total Project Cost. 
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On-Road Heavy-Heavy Duty Diesel Trucks (M-TRAN-3) 

Source Category: 

This category includes all on-road heavy-heavy duty diesel trucks with a gross vehicle 

rate rating of 33,001 pounds or greater. According to ARB estimates, approximately 

67,309 of these trucks operate within the San Joaquin Valley and according to ARB, 

over 28% of the statewide vehicle miles traveled by these trucks occur within the San 

Joaquin Valley. By 2020, the vehicle miles traveled is expected to increase by 

approximately 50% with the number of heavy-duty trucks operating in the San Joaquin 

Valley increasing to approximately 80,042 vehicles. 

Heavy-heavy duty diesel trucks are grouped into categories according to their certified 

engine emission rating, which refers to a model year group. Currently, there are eight 

model year groups: pre-1987, 1987-1990, 1991-1993, 1994-1997, 1998-2002, 2003-

2006, and 2010 and newer. 

POPULATION BY MODEL YEAR GROUPS AT CRITICAL YEARS

MODEL YEAR POPULATION

GROUP 2008 2010 2012 2017 2020 2023 

pre-1987 7,087 5,320 3,975 1,729 986 562 

1987-1990 7,607 6,028 4,519 2,007 1,217 712 

1991-1993 5,834 5,110 4,122 1,886 1,129 692 

1994-1997 14,215 13,056 11,500 6,457 3,814 2,254 

1998-2002 16,569 16,972 16,375 11,620 8,013 4,947 

2003-2006 9,646 10,254 10,699 9,942 7,939 5,892 

2007-2009 5,339 8,540 8,832 9,162 8,324 6,695 

2010+ 0 3,233 10,730 33,726 48,620 61,963

Total 66,297 68,513 70,751 76,509 80,042 83,716

Upcoming Regulations: 

ARB has already adopted several Fleet Rules regulating various industries and is 

currently working on regulations pertaining to on-road heavy-duty diesel trucks. 

Additional regulations are under development to reduce diesel particulate matter (PM) 

and other emissions from private fleets of in-use heavy-duty diesel powered trucks 

operated in California. ARB is in the information-gathering phase for this regulation and 

conducted its first set of workshops for this measure in April of 2006. 

ARB also operates the Heavy-Duty Diesel In-Use Strategies Program, which develops 

and implements strategies to significantly reduce emissions from all existing on- and offroad diesel engines. However, their program emphasizes the reduction of diesel 

particulate emissions. 
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The current emission standard for 2007 trucks is 3.67 grams per mile and will drop to 

0.67 grams per mile in 2010. However, no further decreases in truck emission levels 

are projected. In analyzing various scenarios, engine deterioration rates must be 

factored into all scenarios to show realistic adjustments. 

Control Techniques: 

Various options for controlling emissions are listed below: 

1. Accelerated Fleet Turnover by replacing older trucks with new trucks, which utilize 

the cleanest technology available. 

2. Retrofitting of trucks through the installation of a retrofit device that reduce one or 

more pollutants. 

3. Engine Repower by replacing the truck engines with new or newer engines. 

Emission Inventory and Possible Emission Reductions with no Constraints:

Replace 100% of heavy-duty trucks as soon as the newest technology becomes 

available. The total cost to replace these 134,467 trucks is approximately 

$17,953,340,337. Regulated vehicles were removed from the baseline inventory for this 

analysis.

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2010 2012 2020 2023 

Projected Inventory with no Incentives 237.26 213.20 184.13 96.11 81.82 

No Constraints Inventory 124.72 37.34 45.21 62.98 65.82 

No Constraints Reductions 112.54 175.86 138.92 33.13 15.99 

Potential VOC Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2010 2012 2020 2023 

Projected Inventory with no Incentives 17.08 15.61 13.97 8.36 7.34 

No Constraints Inventory 5.56 4.08 4.85 6.18 6.31 

No Constraints Reductions 11.52 11.53 9.12 2.18 1.03 

Possible Strategies:

Although older trucks have higher emissions, in terms of grams per mile, they are driven 

less, therefore have less overall emissions. An optimal scenario must identify a group 

of trucks that can achieve meaningful emission reductions early, while leaving sufficient 

resources for eventual replacement of trucks with the cleanest control technology, which 
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will be available in 2010. Here are the emissions in key years per truck model year 

groups. 

NOX EMISSIONS INVENTORY TABLE 

2008 2010 2012 2015 2020 

# of 

Trucks 

Emissions 

(tons/day) 

# of 

Trucks 

Emissions 

(tons/day)

# of 

Trucks

Emissions 

(tons/day)

# of 

Trucks

Emissions 

(tons/day) 

# of 

Trucks

Emissions

(tons/day)

pre1987 7,087 7.83 5,320 4.84 3,975 2.95 2,472 1.36 986 0.39 

1987-

1990 7,607 15.57 6,028 10.83 4,519 7.09 2,722 3.31 1,217 0.81 

1991-

1993 5,834 17.89 5,110 13.66 4,122 9.72 2,700 5.24 1,129 1.4 

1994-

1997 14,215 57.93 13,056 45.6 11,500 34.8 8,566 21.41 3,814 6.84 

1998-

2002 16,569 94.28 16,972 83.9 16,375 69.71 13,807 47.05 8,013 19.78 

2003-

2006 9,646 33.7 10,254 34.76 10,699 33.39 10,733 27.91 7,939 14.67 

2007-

2009 5,339 10.04 8,540 19.37 8,832 13.18 9,184 19.07 8,324 8.82 

2010+ 0 0 3,233 1.81 10,730 0 24,069 18.02 48,620 38.93 

VOC EMISSIONS INVENTORY TABLE 

2008 2010 2012 2015 2020 

 # of 

Trucks 

Emissions 

(tons/day) 

# of 

Trucks 

Emissions 

(tons/day)

# of 

Trucks

Emissions 

(tons/day)

# of 

Trucks

Emissions 

(tons/day) 

# of 

Trucks

Emissions

(tons/day)

pre1987 7,087 1.51 5,320 0.98 3,975 0.63 2,472 0.32 986 0.1 

1987-

1990 7,607 2.53 6,028 1.81 4,519 1.21 2,722 0.58 1,217 0.15 

1991-

1993 5,834 1.35 5,110 1.07 4,122 0.79 2,700 0.44 1,129 0.13 

1994-

1997 14,215 4.11 13,056 3.4 11,500 2.7 8,566 1.74 3,814 0.58 

1998-

2002 16,569 5.49 16,972 5.31 16,375 4.7 13,807 3.39 8,013 1.52 

2003-

2006 9,646 1.55 10,254 1.86 10,699 1.99 10,733 1.84 7,939 1.06 

2007-

2009 5,339 0.45 8,540 0.91 8,832 1.15 9,184 1.29 8,324 0.99 

2010+ 0 0 3,233 0.19 10,730 0.75 24,069 1.85 48,620 3.81 
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Scenario 1: All heavy-duty trucks are immediately replaced with the cleanest 

technology available 

The table below shows the affect that this type of incentive program would have on the 

expected NOx emissions in the 2008, 2012, 2020, and 2023 inventory years. 

Tons NOx Per Day – Summer Season 

Scenario 1 2008 2010 2012 2017 2020 2023 

Baseline 237.26 213.20 184.13 120.98 96.11 81.82 

Adjusted 

Baseline 124.72 37.74 45.21 58.69 62.98 65.82 

Reductions 

from Baseline 112.54 175.85 138.92 62.29 33.13 15.99 

Tons VOC Per Day – Summer Season 

Scenario 1 2008 2010 2012 2017 2020 2023 

Baseline 17.08 15.61 13.97 10.05 8.36 7.34 

Adjusted 

Baseline 5.56 4.08 4.85 5.93 6.18 6.37 

Reductions 

from Baseline 11.52 11.53 9.12 4.11 2.18 1.03 

Scenario 1 Total Estimated 

Cost Vehicles Replaced 

Replace 100% of trucks are 

replaced as the cleanest 

technology becomes available

$17,953,340,337 134,467

Advantages: 

• Early reductions in emissions, beginning in 2008 

• Significant NOx reductions 

Disadvantages: 

• Manufacturing constraints 

• Excessive costs 

• Access to trucks may be limited due to trucks registered outside of the 

District 

Scenario 2: Engine Repower (table not included)
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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Advantages: 

• More cost-effective incentive option 

Disadvantages: 

• Emission reductions are not lasting 

• Engine repower is expensive and does not maximize emission reductions 

• Money invested in trucks may exceed the value of the truck 

Scenario 3: Truck Retrofit Devices (table not included)

Advantages: 

• Most cost-effective incentive option 

Disadvantages: 

• Disinterest by the public in installing retrofit devices 

• Retrofits also require expensive maintenance 

• Retrofits may impose a fuel penalty 

Scenario 4: Replace 75% of 1991-1993 model year trucks in 2008 and 2009 

(approximately 3,000 trucks per year) and require a 50% funding match from grant 

recipient 

Tons NOx Per Day – Summer Season 

Scenario 4 2008 2010 2012 2015 2017 2020 2023 

Baseline 237.26 213.20 184.13 143.46 120.98 96.11 81.82 

Adjusted 

Baseline 233.21 209.16 181.23 142.32 120.68 95.96 81.38 

Reductions 

from Baseline 4.05 4.04 2.90 1.14 0.3 0.15 0.44 

Tons VOC Per Day – Summer Season 

Scenario 4 2008 2010 2012 2015 2017 2020 2023 

Baseline 17.08 15.61 13.97 11.49 10.05 8.36 7.34 

Adjusted 

Baseline 16.60 15.08 13.56 11.27 9.91 8.27 7.24 

Reductions 

from Baseline 0.47 0.53 0.41 0.22 0.13 0.09 0.09 

As shown above, this scenario will result in early emission reductions in 2008 and 2009, 

while leaving most of the funding available for use in later years when the cleanest 

technology will be available. 

Scenario 4 Total Estimated 

Cost Trucks Replaced 

Replace 75% of 1991-1993 $456,704,988 3,468 
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model year trucks between 

2008 and 2009 

 

 Advantages: 

• Early reductions 

• Maximizes cost-effectiveness 

Disadvantages: 

• Initial costs may be high 

Scenario 5: In addition to Scenario 4, beginning in 2010, each year replace 10% of the 

remaining pre-2007 truck fleet that are at least 3 years from replacement and require a 

50% match from grant recipients 

Tons NOx Per Day – Summer Season 

Scenario 5 2008 2010 2012 2015 2017 2020 2023 

Baseline 237.26 213.20 184.13 143.46 120.98 96.11 81.82 

Adjusted 

Baseline 233.21 193.70 148.13 104.39 86.37 72.37 70.04 

Reductions 

from Baseline 4.05 19.50 36.00 39.07 34.61 23.74 11.77 

Tons VOC Per Day – Summer Season 

Scenario 5 2008 2010 2012 2015 2017 2020 2023 

Baseline 17.08 15.61 13.97 11.49 10.05 8.36 7.34 

Adjusted 

Baseline 16.60 14.03 11.27 8.59 7.47 6.64 6.48 

Reductions 

from Baseline 0.47 1.58 2.70 2.90 2.58 1.72 0.86 

As shown above, this scenario results in reductions beginning in 2010 and continuing 

through 2023. The estimated total cost involved with this incentive option is highlighted 

in the table below. 

Scenario 5 Total Estimated 

Cost Trucks Replaced 

Beginning in 2010 replace 

10% of the remaining pre2007 fleet annually, at least 

3 years from replacement 

$4,174,781,627 28,089 

Advantages: 

• Cost-effectiveness is retained by focusing only on pre-2007 trucks 

• Increased NOx emission reductions are achieved throughout 2010 to 2023 
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Disadvantages: 

• No effect on 2008 and 2012 NOx emission inventories 

• 100% participation in 2020 unlikely 

Recommendation: 

Replace 75% of 1991-1993 model year trucks requiring a 50% match, in 2008 and 2009 

(approximately 3,000 trucks per year) and beginning in 2010, each year replace 10% of 

the remaining pre-2007 truck fleet that are at least 3 years from replacement requiring a 

50% match. 

Recommended Strategy

Total Project Cost $4,174,781,627

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $2,087,390,813

Total Incentive Funds Needed (Cost) $2,087,390,813

Existing Available Funding $328,338,180

New Funding Required $1,759,052,634
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Passenger and Medium Duty Vehicles (M-TRAN-7)

Source Category: 

This group includes passenger cars, vans, pick-up trucks, and other trucks less than 

8,500 pounds gross vehicle weight. In 2006, this included approximately 1,042,718 

passenger vehicles (vehicles less than 3,750 pounds, such as a sedans); 293,572 lightlight duty trucks (trucks less than 3,750 pounds, such as small single cab pick-up 

trucks); 488,116 light-duty trucks (trucks 3,751-5,750 pounds, such as double cab pickup trucks); and 278,918 medium-duty vehicles (trucks 5,751-8,500 pounds, such as 

very large heavy duty trucks and large sport utility vehicles). 

Out of these approximately 2 million vehicles, approximately 43,000 are classified as 

gross polluters. A gross polluter is a vehicle that fails a California smog test and is 

found to emit 50% more CO, VOC, and/or NOx than the California standards for a 

vehicle of that age. In 2006, gross polluters and cars manufactured before 1986 

traveled a total of over 26,255,000 miles in the San Joaquin Valley. 

Upcoming Regulations:

ARB has implemented several regulations to reduce emissions from vehicles. From 

1994-2003, ARB adopted low emitting vehicle (LEV) standards that required specific 

percentages of vehicles manufactured or the average emissions from all vehicles 

manufactured by a company to meet specific emission standards. Due to these 

standards, the average LEV I vehicle emits about 98% less smog forming hydrocarbons 

during its lifetime than a 1965 vehicle. 

ARB has created regulations/advisories to set new standards (LEV II, Ultra Low 

Emission Vehicle (ULEV), Super Ultra Low Emission Vehicle (SULEV), Partial Zero 

Emission Vehicle (PZEV), Advanced Technology Partial Zero Emission Vehicle (ATPZEV), and Zero Emission Vehicle (ZEV)) to reduce the maximum emission limits for 

new vehicles; increase the time that manufacturers must design the new vehicles to 

comply with these standards (durability); tighten and expand the applicability of average 

emission limits for commercial fleets and for vehicle manufacturers; and expand the 

applicability of the LEV II standards to include over 90% of the sport utility vehicles, 

virtually all pickup trucks, and most mini-vans. The average LEV II vehicle 

manufactured in 2008 emits 80% less smog forming hydrocarbons during its life than a 

comparable 1998 LEV I vehicle. 

Currently, the majority of vehicles manufactured in the United States are at a LEV II or 

cleaner standard. Therefore, older vehicles are naturally being replaced with cleaner 

vehicles. Approximately 25% of the new vehicles are at a straight LEV II standard, 65% 

meet the ULEV standard, and 10% are at a standard more stringent than the ULEV 

standard. Approximately 8% reduction in NOx and 6% reduction in VOC emissions per 

year are expected from natural turnover of vehicles in the next year (2007-2008), 

decreasing slightly each year thereafter. In 2020, approximately 7% reduction in NOx 

and 3% reduction in VOC emissions per year are expected from natural turnover of 
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vehicles. In 2023, approximately 10% reduction in NOx and over 10% reduction in VOC 

emissions per year are expected from natural turnover of vehicles due to advances in 

technology. The emission limits for vehicles have consistently decreased over the 

years. It is expected that these limits, thus the emission limits for gross polluters, will 

continue to decrease due to the California Air Resources Board (ARB) regulations.

Control Techniques: 

There are several options for the control of emissions from passenger and medium-duty 

vehicles. 

1. Since, in many cases, the repairs required to minimize emissions from gross 

polluting vehicles exceeds the cost limits of the California Smog Check Program, 

many of these vehicles are not repaired to the maximum extent. The District could 

fund the difference between the maximum cost limit of the Smog Check Program 

and the cost of the repairs necessary to minimize emissions from these vehicles. 

2. Since there are various emission standards (pre-LEV I, LEV I, LEV II, ULEV, 

SULEV, PZEV, AT-PZEV, and ZEV), the District could incentivize the replacement of 

a vehicle (crush and permanently remove from service) with a vehicle that has a 

cleaner technology. 

3. The District could promote alternatives to driving, such as bicycling and carpooling, 

by incentivizing the installation of bicycle paths and other items that promote bicycle 

use; incentivizing use of public transportation systems such as buses; incentivizing 

use of commercial and private vanpools and carpools; and incentivizing the 

purchase of telecommunication equipment for projects that promote the reduction of 

vehicle miles traveled, such as video teleconferencing, internet business 

transactions for public agencies, telework sites and distance learning. 

Emission Inventory and Possible Emission Reductions with no Constraints: 

If, beginning in 2008, the District replaced every passenger vehicle that did not meet 

current model year average emission or more stringent standards with a ULEV vehicle 

the reductions shown in the table below could be achieved. Under this assumption, the 

District would pay the entire cost of the 1.6 million vehicles at a cost of over $20 billion. 

This assumes that some vehicles will be replaced more than once, as technology 

availability increases. 

If, beginning in 2008, the District paid the entire cost of replacing every light-light duty 

truck that did not meet current model year average emission or more stringent 

standards with a ULEV vehicle, over 270,000 vehicles would be replaced at a cost of 

over $3 billion. This assumes that some vehicles will be replaced more than once, as 

technology availability increases. 

If, beginning in 2008, the District paid the entire cost of replacing every light duty truck 

that did not meet current model year average emission or more stringent standards with 

a ULEV vehicle, over 450,000 vehicles would be replaced at a cost of over $6 billion. 
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This assumes that some vehicles will be replaced more than once, as technology 

availability increases. 

If, starting in 2008, the District replaced every medium duty truck that did not meet 

current model year average emission or more stringent standards with a new passenger 

vehicle that meets the current year standards every year, an average of 5.0 tons per 

day of VOC and 5.5 tons per day of NOx could be achieved each day from 2008 to 

2023. If the District paid the entire cost of the new vehicles, this would result in over 

340,000 vehicles being replaced at a cost of over $5 billion. This assumes that some 

vehicles will be replaced more than once, as technology availability increases. 

Incorporating all of the aforementioned controls would achieve VOC reductions of 28.3 

tons per day and NOx reductions of 21.38 tons per day. However, it would involve the 

replacement of over 2.6 million vehicles (assuming some vehicles will be replaced more 

than once). It also would cost over $34 billion dollars over the next 15 years and require 

additional car crushing capacity in the District. 

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 49.4 36.9 24.3 19.4 16.1 

No Constraints Inventory 28.3 21.9 15.2 12.4 13.3 

No Constraints Reductions 21.1 15.0 9.2 7.0 2.8 

Potential VOC Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 53.5 42.4 31.1 27 7.4 

No Constraints Inventory 34.1 27.39 20.36 17.86 3.9 

No Constraints Reductions 19.4 15.01 10.74 9.14 3.5 

Possible Strategies: 

Alternative transportation options, including carpooling, were not considered feasible 

measures for the plan. This is due to the inability to accurately quantify these 

reductions. There are limited methodologies for calculating reductions from any of 

these options, all of which tend to overestimate reductions. Even using these numbers, 

the potential reductions from 2008 to 2023 would only total approximately 205 tons from 

2008-2023. This comes at a cost of approximately $16,000 per ton reduced. 

Additionally, there is minimal interest in many of these options. Less than 14% of the 

grant applications received from the District are from alternative transportation projects, 

such as commuter subsidies, bicycle infrastructure, and E-mobility. In order to 

maximize the emission reductions per dollar spent and minimize staff time spent on 
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measures with minimal emission reductions, these options were not considered 

reasonable for inclusion in the Ozone Plan. 

Repairing vehicles that did not pass Smog Check is not feasible because approximately 

7% of these vehicles do not pass smog check the next time they are tested. Therefore 

it is not feasible to quantify these reductions. 

The above scenarios are also not feasible because there are a limited number of 

vehicles that can be manufactured per year. Not everyone will want to participate in this 

program, even with 100% funding, some of the vehicles may be collectors' items or 

have a personal attachment. The cost-effectiveness of replacing some of these 

vehicles, particularly those less than 5 years old, would greatly exceed the costeffectiveness of alternative incentive projects. 

Finally, the aforementioned reductions are not reasonable because it is not possible to 

accurately predict public response and participation in the program or future legislations 

that may enable another entity to claim these reductions. 

Scenario 1: Replacement of 10% of the worst polluting vehicles each year

Gross polluters emit the majority of the NOx and VOC emissions from vehicles, but 

account for less than 20% of the vehicles. Thus a plausible scenario would be to only 

replace the highest emitters of the gross polluters with LEV II vehicles (limiting it to LEV 

II instead of current year models or more advanced technology will allow applicants to 

take advantage of lower priced used vehicles, while still ensuring emission reductions). 

This would minimize the number of vehicles replaced and ensure that the maximum 

average reductions per vehicle replaced were achieved. This option recommends 

replacing 10% of the vehicles each year from 2008 through 2023. The reductions and 

costs from this option are shown below. The calculations assume a one-year project life 

because these vehicles would typically undergo smog testing within 1-2 years. Once a 

vehicle fails the smog check, the Bureau of Automotive Repair (BAR) likely claims the 

reductions. In order for the District to claim reductions, these vehicles must be identified 

and removed from use while off-cycle (1 to 2 years prior to their next smog check). 

Tons NOx Per Day – Summer Season 

Scenario 1 2008 2012 2017 2020 2023 

Baseline 49.4 36.9 24.3 19.4 16.1 

Adjusted Baseline 

10% of the worst polluting 

vehicles replaced annually 

48.6 36.4 23.9 19.3 15.8 

Reductions from Baseline 0.8 0.5 0.4 0.1 0.3 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Tons VOC Per Day – Summer Season 

Scenario 1 2008 2012 2017 2020 2023 

Baseline 53.5 42.4 31.1 27 7.4 

Adjusted Baseline 

10% of the worst polluting 

vehicles replaced annually 

52.4 41.9 31.0 26.6 6.9 

Reductions from Baseline 1.2 0.5 0.1 0.4 0.5 

As shown above this scenario results in significant reductions in 2008. However, as 

shown below the total cost is significant. 

Scenario 1 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

10% of the worst polluting 

vehicles replaced annually $54,922,076 $16,735 

Scenario 2: Replace between 1% and 2% each year from 2008 to 2020 

This scenario considers replacing 5% of the worst polluting model year 1978-2004 

vehicles gradually from 2008 through 2020. In the first two years 1% of the gross 

polluting vehicles are replaced; in the next two years 2% of the gross polluting vehicles 

are replaced, in the next eight years three percent of the gross polluting vehicles are 

replaced. This would mean replacing approximately 5,380 vehicles over a twelve year 

period. This allows manufacturers, venders, and service providers (e.g. crushers) time 

to gradually expand their capacity to facilitate the replacements. This assumes a oneyear project life because these vehicles would typically undergo smog testing within 1-2 

years after which the BAR would claim the reductions. 

Tons NOx Per Day – Summer Season 

Scenario 2 2008 2012 2015 2017 2020 2023 

Baseline 49.4 36.9 31.4 24.3 19.4 16.1 

Replace 1% to 4% each year 

between 2008 and 2020 48.6 36.5 31.1 24.2 19.4 15.8 

Reductions from Baseline 0.8 0.4 0.3 0.1 0.1 0 

Tons VOC Per Day – Summer Season 

Scenario 2 2008 2012 2015 2017 2020 2023 

Baseline 53.5 42.4 31.3 31.1 27 7.4 

Replace 1% to 4% each year 

between 2008 and 2020 52.4 41.9 31.1 31.0 27 6.9 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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Reductions from Baseline 1.1 0.54 0.2 0.12 0.1 0 

The reductions in this scenario are less than Scenario 1, however the total cost is 

significantly less. 

Scenario 2 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Replace 1% to 4% each 

year between 2008 and 

2020 

$38,445,454 $16,735 

Scenario 3: Replace between 10% and 25% of the highest emitting vehicles each year 

from 2008 to 2020- approximately 2,948 vehicles per year 

This scenario considers replacing 10% to 25% of the worst polluting model year 1978-

2004 vehicles gradually from 2008 through 2020. The percentage of vehicles replaced 

each year will vary, but the number will be approximately 2,948 vehicles. This allows 

manufacturers, venders, and service providers (e.g. crushers) to predict the number of 

vehicles that will be crushed to allow the expansion of their business infrastructure and 

staffing accordingly. 

Tons NOx Per Day – Summer Season 

Scenario 3 2008 2012 2015 2017 2020 2023 

Baseline 49.4 36.9 31.4 24.3 19.4 16.1 

Replace approximately 2,948 

vehicles each year between 

2008 and 2020 

48.41 36.02 30.49 23.47 18.65 16.1 

Reductions from Baseline 0.99 0.88 0.91 0.83 0.75 0 

Tons VOC Per Day – Summer Season 

Scenario 3 2008 2012 2015 2017 2020 2023 

Baseline 53.5 42.4 31.3 31.1 27.0 7.4 

Replace approximately 2,948 

vehicles each year between 

2008 and 2020 

52.15 41.19 30.05 29.96 25.97 7.4 

Reductions from Baseline 1.35 1.21 1.25 1.14 1.03 0 

The reductions in this scenario are less than Scenario 1, however the total cost is 

significantly less. 

Scenario 3 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Replace 1% to 4% each 

year between 2008 and 

2020 

$176,900,000 $16,735 

Recommendation: 

Scenario 3 is recommended. This scenario minimizes the number of incentivized 

vehicles that, due to natural turnover, would not be present in 2020, one of the key 

attainment years. It also allows industry to predict the number of vehicles crushed each 

year and have confidence that this volume will continue for over a decade, thus 

expanding their business to meet the demand. This scenario would be implemented, 

provided additional funding becomes available. If funding does not become available, 

the District would proceed with Scenario 2. 

Under this scenario, up to $5,000 will be offered to the owners of high-emitting vehicles 

for the purchase of qualifying clean vehicles. The recipients will be required to enter 

into legally binding contracts to ensure the purchase and operation of the clean vehicles 

for a specified period of time. Alternatively, owners of high emitting vehicles may be 

offered a clean replacement vehicle if a sufficient pool of such vehicles can be created 

through tax incentives legislation such as SB23 (Cogdill, 2007). 

Recommended Strategy

Total Project Cost $176,900,000

Grant Recipient Match (Percent) 30%

Grant Recipient Match (Cost) $53,070,000

Total Incentive Funds Needed (Cost) $123,830,000

Existing Available Funding $26,911,818

New Funding Required $96,918,182
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Construction and Mining Equipment (M-IND-5)

Source Category:

This source category includes engines in construction and mining equipment. 

Upcoming Regulations: 

Regulations requiring reformulation of gasoline and diesel will likely change the 

emission factors, although the current emission inventory, based on the OFFROAD 

model, reflects implementation of Phase 3 gasoline and current Tier standards, 

considering natural fleet turnover. 

ARB is considering fleet regulations for construction, material handling, cargo handling, 

port, and rail yard equipment. Based on the current proposal, by 2013 virtually all offroad equipment would be at the highest Tier level technologically feasible. Idling 

limiting technology is being proposed to minimize idling time (considering natural 

turnover, regulated turn-over, and idle time reduction requirements). There are a few, 

small segments of this category that will have until 2015 or 2020 to comply with control 

technology requirements, however the emissions from these sources with a longer 

compliance time are less than 0.1 tons per day. In terms of exemption, virtually every 

person with more than one piece of equipment will be captured in the definition of 

medium or large fleets proposed by ARB. 

Control Techniques: 

There are several options for controlling emissions from construction and mining 

equipment. 

1. Retrofit with a diesel exhaust catalyst or selective catalytic converter. 

2. Repower (replace the engine with a cleaner engine). 

3. Replace the entire equipment with a newer piece of equipment at a cleaner Tier 

level (e.g. conversion of a Tier 0 to a Tier 3). 

Emission Inventory and Possible Emission Reductions with no Constraints: 

If every piece of off-road equipment was replaced every year to the cleanest available 

technology (highest feasible tier), the following reductions could be achieved. It also 

assumes that, in any category where it is technologically feasible, the engines are 

electrified and that some pieces of equipment will be replaced multiple times. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 48.1 37.4 24.8 20.0 16.7 

No Constraints Inventory 1.9 1.5 1.0 0.8 0.7 

No Constraints Reductions 46.2 35.9 23.8 19.2 16.0 

Potential VOC Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 53.5 42.4 31.1 27 7.4 

No Constraints Inventory 7.5 5.9 4.4 3.8 1.0 

No Constraints Reductions 46.0 36.5 26.7 23.2 6.4 

Possible Strategies:

The aforementioned reductions are not feasible because there are not a sufficient 

number of Tier 4 engines currently manufactured to accomplish this option. 

Furthermore, there are not enough trained people to perform the engine replacements 

to accomplish this option. Also, these reductions may not be SIP creditable and ARB's 

proposed regulations are expected to claim most of the available reductions. Finally, 

implementation of the aforementioned incentives is contingent upon funds being 

available. Therefore, it is likely that the reductions from this measures will be less than 

those listed in the above table. 

Retrofits (e.g. oxidative catalysts, low-NOx catalysts, exhaust gas recirculation, 

particulate filters, oxidation catalysts) were not considered a viable option because there 

is not a significant benefit for a person to choose to retrofit an existing piece of 

equipment, even if the retrofit is completely funded. This is due to the fact that the 

retrofit device will result in higher fuel and maintenance costs for the end user. 

Furthermore, there are inconveniences associated with anhydrous ammonia or urea to 

be used as a reductant for the selective catalytic converter in the District. 

Conversion of the equipment to electric is not feasible because there has not been a 

strong market demand for this option. In many cases, electricity is not a viable energy 

source, particularly for equipment used for extended periods of time or on rough terrain. 

Most mining equipment and construction equipment, at some point, operates under 

these conditions. 

Conversion to alternative fuels is not highly demanded. This is because alternative 

fuels tend to have lower energy content per volume, are less readily available, are 

harder to transport, are more expensive to store, and are more expensive to dispense. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

7-34

Early replacement of old engines with newer engines is not feasible in many cases. 

This is due to the fact that the engine compartment in a piece of equipment with a Tier 0 

or 1 engine may not be large enough to hold a Tier II, III, or IV engine. In some cases, 

the labor cost to repower an old engine is more than the cost to purchase a used or new 

piece of equipment with a cleaner engine. Another consideration is that thousands of 

dollars can be spent replacing engines in equipment that are worth less than the cost of 

the repower. 

Finally, replacing equipment is typically not an option due to poor cost effectiveness and 

high costs. The cost of a new boom is around $975,000 and a used bulldozer with an 

850 horsepower engine is over $800,000. Thus, less than 25 replacements could 

exceed the entire District’s incentive program budget for 2006-2007. 

Possible Strategies:

Scenario 1: Replacement of 20% of the engines starting in 2008 to the newest 

available, and technologically feasible, at the time of replacement 

The table below shows the numbers associated with this option. 

Tons NOx Per Day – Summer Season 

Scenario 1 2008 2012 2017 2020 2023 

Baseline 49.4 36.9 24.3 19.4 16.1 

Adjusted Baseline 

Replace 20% of engines to 

the cleanest available 

beginning in 2008 

40.5 30.3 19.9 15.9 13.2 

Reductions from Baseline 8.9 6.6 4.4 3.5 2.9 

Tons VOC Per Day – Summer Season 

Scenario 1 2008 2012 2017 2020 2023 

Baseline 53.5 42.4 31.1 27 7.4 

Adjusted Baseline 

Replace 20% of engines to 

the cleanest available 

beginning in 2008 

48.2 38.2 28.0 24.3 6.7 

Reductions from Baseline 5.35 4.24 3.11 2.7 0.74 

Scenario 1 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Replace 20% of engines to 

the cleanest available 

beginning in 2008 

$162,355,000 $10,228 

Scenario 2: Replacement of 10 compacters, 10 crawler dozers, 10 earth movers, 10 

motor graders, and 10 scrapers each year from 2008 to 2023 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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The table below shows the numbers associated with this option. 

Tons NOx Per Day – Summer Season 

Scenario 2 2008 2012 2015 2017 2020 2023 

Baseline 48.1 37.4 47.8 24.8 20.0 16.7 

Replace 10 compacters, 10 

crawler dozers, 10 earth 

movers, 10 motor graders, 

and 10 scrapers between 

2008 and 2023 

47.9 36.1 46.2 23.0 18.1 14.9 

Reductions from Baseline 0.3 1.3 1.6 1.8 1.8 1.8 

Tons VOC Per Day – Summer Season 

Scenario 2 2008 2012 2015 2017 2020 2023 

Baseline 53.5 42.4 42.2 31.1 27 7.4 

Replace 10 compacters, 10 

crawler dozers, 10 earth 

movers, 10 motor graders, 

and 10 scrapers between 

2008 and 2023 

53.5 42.3 42.1 31.0 26.9 7.26 

Reductions from Baseline 0.02 0.1 0.1 0.1 0.1 0.1 

Scenario 2 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Replace 10 compacters, 10 

crawler dozers, 10 earth 

movers, 10 motor graders, 

and 10 scrapers between 

2008 and 2023 

$66,108,900 $5,831 

Recommendation: 

Scenario 2 is recommended because it targets the most cost-effective replacements. It 

also spreads the reductions over the entire time period to minimize emissions, thus 

detrimental heath efforts due to ozone, for the entire 15 year period. 

Recommended Strategy

Total Project Cost $66,108,900

Grant Recipient Match 

(Percent) 20%

Grant Recipient Match (Cost) $13,221,780

Total Incentive Funds Needed 

(Cost) $52,887,120
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

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Existing Available Funding $52,887,120

New Funding Required $0

Compression Ignited Agricultural Engines (S-COM-6)

Source Category:

This source category includes compression ignited agricultural engines greater than 50 

horsepower and operated in the District. According to the recent District Rule 4702 staff 

report, there are approximately 4,542 agricultural engines currently powering irrigation 

pumps in the District. In 2006, these engines consisted of 1,915 uncontrolled engines, 

1,641 Tier 1 engines, 941 Tier 2 engines, and 45 Tier 3 engines. The horsepower 

ratings of these engines varied from 50 to 750 horsepower and had average annual 

operating times of 1,000 to 1,500 hours. Due to upcoming regulations, the distribution 

of these engines throughout the Tier levels will change. The populations of engines at 

each Tier level, at the critical years, are shown in the table below. 

POPULATION BY TIER LEVEL AT CRITICAL YEARS

MODEL YEAR POPULATION

GROUP 2012 2017 2020 2023 

Uncontrolled 0 0 0 0 

Tier 1 1,641 0 0 0 

Tier 2 941 0 0 0 

Tier 3 1,960 1,960 1,960 1,960 

Tier 4 0 2,582 2,582 2,582 

Total 4,542 4,542 4,542 4,542 

Upcoming Regulations: 

District Rule 4702 regulates NOx emissions from stationary spark-ignited engines and 

stationary compression ignited (diesel) engines greater than 50 horsepower. District 

Rule 4702 requires that non-certified engines, depending on horsepower and hours of 

operation, must comply with EPA certified Tier 3 or Tier 4 emissions by 2010. EPA 

certified Tier 1 or Tier 2 engines must comply with Tier 4 standards by 2015 or 12 years 

after installation date whichever is later. 

Control techniques:

The following control techniques are available to reduce NOx emissions below the 

current emission level: 

1. Replacement of existing agricultural diesel engines with cleaner diesel engine and/or 

electric motor. 

2. Replacement of existing agricultural pumps with a new high efficiency pump. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

7-37

Emission Inventory and Possible Emission Reductions with no Constraints: 

The no constraints emission reductions estimated below assume electrification of all 

agricultural pumps. The total cost is approximately $185, 059,621. The costeffectiveness of this option is approximately $5,656 per ton of NOx reduced, if all 

agricultural engines are replaced in 2008. 

Potential NOx Emission Reductions Assuming No 

Financial, 

Technological, or Implementation Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no 

Incentives 22.41 15.46 4.64 4.64 4.64

No Constraints Inventory 0 0 0 0 0

No Constraints Reductions 22.41 15.46 4.64 4.64 4.64

Possible Strategies: 

Scenario 1: Replace all Tier 0 agricultural engines with Tier 3 diesel engines by 2009 

and replace all Tier 1 and Tier 2 engines with Tier 4 by 2014 and electrification of 50% 

of high use Tier 3 engines between 2020 and 2023. Additionally, implement a pump 

efficiency replacement for 10% of diesel engines annually beginning in 2008. 

• NOx Reduction - 4.13 tons per day in 2008 

- 10.91 tons per day in 2014 

- 1.89 tons per day in 2017 

- 2.07 tons per day in 2023 

• Total Cost - $171,518,370 

Scenario 2: Electrification of all existing agricultural engines in 2008 (Note: 

Electrification is not feasible for portable engines. Electrification is also not feasible for 

many stationary engines due to issues with availability of electricity at certain sites and 

potential high line extension costs.) 

• NOx Reduction - 22.41 tons per day 

• Total Cost - $129,541,735 

Scenario 3: Electrification of all existing agricultural engines before 2012 by replacing 

approximately 900 engines each year (Note: Electrification is not feasible for portable 

engines. Electrification is also not feasible for many stationary engines due to issues 

with availability of electricity at certain sites and potential high line extension costs.) 

• NOx Reduction - 15.46 tons per day 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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• Total Cost - $141,376,137 

Recommendations: 

Replace all Tier 0 engines with Tier 3 engines by 2009. Replace all Tier 1 and Tier 2 

engines with Tier 4 engines by 2014. Electrify 50% of Tier 3 engines between 2020 and 

2023. Implement pump efficiency replacement for 10% of diesel engines annually 

beginning in 2008. 

• All 1,915 Tier 0 diesel-fired agricultural engines could conceivably be replaced 

with Tier 3 engines within approximately 2 years (2007–2008) of commencing an 

incentive program. 

o A 2-year replacement timeframe results in approximately 958 diesel-fired 

agricultural engines per year. 

o The total cost of this 2-year program to the District is estimated to be 

$35,522,774, with a cost effectiveness of $2,945 per ton and a reduction 

of 4.13 tons/day. 

• All 2,582 Tier 1 and Tier 2 diesel-fired agriculture engines could conceivably be 

replaced with Tier 4 engines within approximately 2 years (2012–2014) of 

commencing an incentive program. 

o A 2-year replacement timeframe results in approximately 1,291 dieselfired agricultural engines per year. 

o The total cost of this 2-year program to the District is estimated to be 

$64,956,472, with a cost effective analysis of $2,039 per ton and a 

reduction of 10.91 tons/day. 

• 50% of all Tier 3 diesel-fired agriculture engines could conceivably be replaced 

with electric motors within approximately 3 years (2020-2023) of commencing an 

incentive program. 

o A 3-year replacement timeframe results in the replacement of 

approximately 490 diesel-fired agricultural engines per year. 

o The total cost of this 3-year program to the District is estimated to be 

$53,456,577 with a cost effective analysis of $17,933 per ton and a 

reduction of 2.04 tons/day. 

• 10% of agricultural pumps each year could conceivably be replaced with high 

efficiency pumps within 10 years (2008–2017) of commencing an incentive 

program. 

o A 10-year replacement timeframe results in the replacement of 

approximately 450 existing agricultural pumps per year. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

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o The total cost of this 10-year program to the District is estimated to be 

$91,090,420 with a cost effective analysis of $115,775 per ton and a 

reduction of 1.89 tons/day. 

Recommended Strategy

Total Project Cost $245,026,243

Grant Recipient Match (Percent) 30%

Grant Recipient Match (Cost) $73,507,873

Total Incentive Funds Needed (Cost) $171,518,370

Existing Available Funding $102,522,774

New Funding Required $68,995,596
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Spark-Ignited Agricultural Forklifts Exempt from State (M-IND-2)

LSI Regulations 

Source Category: 

This source category includes forklifts used in agricultural crop preparation services, 

specifically agricultural spark-ignited forklifts that cannot be retrofitted with a certified 

emission control device. There are an estimated 800 forklifts within the District that fall 

into this category, most of them manufactured prior to 1990. 

Upcoming Regulations: 

ARB has adopted future fleet emissions standards for spark-ignited forklifts; however, 

agricultural crop preparation service forklifts that cannot be retrofitted with a certified 

emission control device are exempt from these fleet emission standards. 

Control Techniques: 

The emission factor for uncontrolled forklifts is estimated to be approximately 10.5 

g/bhp-hr. The following emission control technologies are available to reduce NOx 

emissions below the current emission level: 

1. Replacement with a new spark-ignited forklift that is capable of achieving a NOx 

emissions rate of 3.0 g/bhp-hr. 

2. Replacement with an electric forklift. 

Emission Inventory and Possible Emission Reductions with no Constraints: 

The no constraints emission reductions estimated below are calculated assuming the 

electrification of all agricultural spark-ignited forklifts. The total cost will be 

approximately $40,962,400. The cost-effectiveness of this option is approximately 

$5,656 per ton of NOx reduced if all of the spark-ignited agricultural forklifts are 

replaced in 2008. 

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 1.23 1.23 1.23 1.23 1.23 

No Constraints Inventory 0.0 0.0 0.0 0.0 0.0 

No Constraints Reductions 1.23 1.23 1.23 1.23 1.23 

Possible Strategies: 

Scenario 1: Replacement of all forklifts with electric forklifts by 2011 

• All 800 spark-ignited forklifts could conceivably be replaced with electric forklifts 

by 2011 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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At an average cost of $47,933 per electric forklift and $3,270 per battery charger, the 

total cost to convert all of the existing 800 spark-ignited agricultural forklifts to electric 

forklifts is estimated to be $40,962,400. 

While this scenario results in the maximum no constraints reduction of 1.23 tons of NOx 

per day, the scenario is unlikely to be achieved. Operational needs and electric forklift 

limitations will prevent most facilities from pursuing electric forklifts. Electric forklifts 

cannot operate continuously without recharging the forklift batteries. Furthermore, 

electric forklifts typically have less torque and lifting capability than their spark-ignited 

counterparts. Therefore, this strategy is not realistic. 

Scenario 2: Replacement of all forklifts with new spark-ignited forklifts by 2011 

• All 800 spark-ignited forklifts could conceivably be replaced with new sparkignited forklifts within approximately 3 years of commencing an incentive program 

• A 3-year replacement timeframe results in approximately 267 forklifts replaced 

per year 

• At an average cost of $27,000 per new spark ignited forklift, the total cost to 

replace the 800 existing spark-ignited agricultural forklifts with electric forklifts is 

estimated to be $21,600,000 

This scenario results in an emissions reduction of 0.88 tons of NOx per day. While this 

Scenario is the least costly of the three Scenarios investigated, some interest in electric 

forklifts is expected since electric forklifts are less costly to operate and maintain. While 

this Scenario is more realistic than Scenario 1, it does not allow for the option to install 

electric forklifts, which further reduces NOx emissions. 

Scenario 3: Replacement of 90% of the forklifts with spark-ignited forklifts and 10% of 

the forklifts with electric forklifts by 2011 

• All 800 spark-ignited forklifts could conceivably be replaced within approximately 

3 years of commencing an incentive program 

• A 3-year replacement timeframe results in approximately 240 forklifts replaced by 

new spark ignited forklifts per year 

• A 3-year replacement timeframe results in approximately 27 forklifts replaced by 

electric forklifts per year 

• At an average cost of $27,000 per spark-ignited forklift, $47,933 per electric 

forklift and $3,270 per battery charger, the total cost of this 3-year program is 

estimated to be $23,536,240 

Scenario 3 reduces NOx emissions by 0.91 tons of NOx per day and is the most 

realistic scenario since it allows for replacement with electric forklifts of a portion of the 

inventory. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

7-42

Recommendation: 

Since electric forklifts are less costly to operate and maintain, some interest in electric 

forklifts is expected. Furthermore, replacement with electric forklifts results in greater 

emission reductions than replacement with new spark-ignited forklifts. Therefore, 

Scenario 3 is the most realistic of the above Scenarios and is recommended. 

Recommended Strategy

Total Project Cost $23,536,240

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $11,768,120

Total Incentive Funds Needed (Cost) $11,768,120

Existing Available Funding $3,000,000

New Funding Required $8,768,120
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Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Off-Road Portable Engines Incentives (M-IND-7) 

Source Category: 

This source category includes facilities that operate portable diesel engines and 

equipment used in a variety of applications such as well drilling & servicing, power 

generation, pumping, gas compression, pile driving, cranes, ground support equipment, 

wood chipping, dredging, abrasive blasting, concrete batching and rock, sand, or gravel 

processing. Based on information provided by ARB, the following table describes the 

inventory of off-road portable engines in the District. 

Population by Tier Level at Critical Years 

Population Tier Rating 2008 2012 2020 2023 

Uncontrolled Tier 0 

engines 2050 1004 193 89 

Tier 1 Tier 1 

engines 2241 1886 491 308 

Tier 2 Tier 2 

engines 1793 1923 1027 478 

Tier 3 Tier 3 

engines 818 1707 1185 982 

Tier 4 Tier 4 

engines 103 535 4093 5284 

Total Total 

engines 7005 7055 6989 7141 

Upcoming Regulations: 

Tier 1-3 Standards: The first federal standards (Tier 1) for new non-road (or off-road) 

diesel engines were adopted in 1994 for engines over 37 kW (50 hp), to be phased-in 

from 1996 to 2000. In 1996, a Statement of Principles (SOP) pertaining to non-road 

diesel engines was signed between EPA, ARB and engine makers (including 

Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, 

Navistar, New Holland, Wis-Con, and Yanmar). On August 27, 1998, the EPA signed 

the final rule reflecting the provisions of the SOP. The 1998 regulation introduced Tier 1 

standards for equipment under 37 kW (50 hp) and increasingly more stringent Tier 2 

and Tier 3 standards for all equipment with phase-in schedules from 2000 to 2008. The 

Tier 1-3 standards are met through advanced engine design, with no or only limited use 

of exhaust gas aftertreatment (oxidation catalysts). Tier 3 standards for NOx+HC are 

similar in stringency to the 2004 standards for highway engines, however Tier 3 

standards for PM were never adopted.

Tier 4 Standards: On May 11, 2004, the EPA signed the final rule introducing Tier 4 

emission standards, which are to be phased-in over the period of 2008-2015. The Tier 

4 standards require that emissions of PM and NOx be further reduced by about 90%. 
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Such emission reductions can be achieved through the use of control technologies, 

including advanced exhaust gas aftertreatment, similar to those required by the 2007-

2010 standards for highway engines. 

Control Techniques: 

The following control technique is available to reduce NOx emissions below the current 

emission level: 

 

1. Replacement of an existing engine, with a lower polluting Tier 3 or 4 engine. 

Tier 3 engines will be phased into production between 2006 and 2008. Tier 4 engines 

are scheduled to be phased into production between 2008 and 2015, with most engine 

manufacturers beginning production between 2011 and 2015. 

Emission Inventory and Possible Emission Reductions with no Constraints: 

For each inventory year in the below table, the no constraints reductions are calculated 

assuming that all engines are replaced with the lowest emitting engines available on the 

market. The cost for the 2008 no constraints scenario is approximately $170,500,000. 

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory 14.0 10.8 7.0 6.0 4.6 

No Constraints Inventory 9.0 7.7 2.0 3.0 3.2 

No Constraints Reductions 5.0 3.1 5.0 3.0 1.4 

Possible Strategies: 

Scenario 1: Replace all engines in 2008 with the cleanest engines available 

• Approximately 4,661 engines would be replaced in 2008 

• The estimated cost to replace all engines with the cleanest Tier level engines 

available in 2008 is approximately $170,500,000 

• This scenario results in an emissions reduction of 5.0 tons of NOx/day in 2008 

While this scenario results in the greatest reduction in NOx emissions in 2008, 

approximately 2.7 tons of NOx/day of the reductions are attributed to replacing Tier 0 

engines. Since most of these engines are required to be replaced by 2010 by ARB Air 

Toxic Control Measure for Portable Diesel Engines, these reductions are already 

scheduled to occur. Furthermore, this scenario proposes to replace 4,661 engines in a 

single year. It is unlikely that 4,661 engines could be manufactured and installed in a 

single year. Furthermore, the total project cost for this scenario is approximately 
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$170,500,000. This level of funding is unlikely for a single year. Therefore, this 

scenario is unrealistic. 

Scenario 2: Replace all Tier 0 and Tier 1 engines with the cleanest available engines 

between 2008 and 2012, then replace all Tier 2 engines with Tier 3 engines between 

2012 and 2016, and finally replace all Tier 3 engines with Tier 4 engines between 2016 

and 2020 

• The total project cost for this scenario is estimated to be $178,892,307, with 

$62,800,000 of the total project cost occurring between 2008 and 2012, 

$56,988,150 of the total project cost occurring between 2012 and 2016, and the 

remainder of the project cost occurring between 2016 and 2020 

• This scenario results in an emissions reduction of approximately 1.4 tons/NOx 

per day in 2012, beyond what is required by the ARB Air Toxic Control Measure 

for Portable Diesel Engines. Additionally, this scenario results in approximately 

1.3 tons of NOx/day of reductions in 2015 and 1.4 tons/NOx per day of 

reductions in 2020 

Recommendation: 

Scenario 2 results in early reductions, provides compliance assistance for facilities to 

meet the ARB Air Toxic Control Measure engine deadlines, and spreads the cost over 

many years. Therefore, staff recommends Scenario 2. 

Recommended Strategy

Total Project Cost $178,892,307

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $89,456,154

Total Incentive Funds Needed (Cost) $89,456,154

Existing Available Funding $16,000,000

New Funding Required $73,456,154
- NOT FOR INCLUSION IN SIP - 

San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Locomotives (M-TRAN-12)

Source Category: 

This source category includes line hauling and switching locomotives. There are an 

estimated 139 line haul locomotives and 59 switching locomotives operating within the 

SJVAPCD. 

Upcoming Regulations: 

• The Air Resources Board Memorandum of Understanding (MOU) with the 

Burlington Northern Santa Fe and Union Pacific rail yards requires the installation 

of Idling Limitation Devices (ILD) on over 99% of interstate locomotives between 

June 30, 2006 and June 30, 2008. Additionally, the MOU requires the use of 

ultra low-sulfur diesel (15 ppm) by January 1, 2007. The MOU includes a phaseout of non-essential idling within 6 months of the MOU inception date and the 

installation of idling reduction devices on all California-based locomotives within 3 

years. 

• Tier 3 locomotive engines will become available in 2012, pending EPA 

promulgation of necessary regulations. 

• In September of 2000, ARB approved a comprehensive Diesel Risk Reduction 

Plan to reduce diesel emissions from both new and existing diesel-fueled 

engines and vehicles. The goal of the plan is to reduce diesel PM emissions and 

the associated health risk by 75% in 2010 and 85% in 2020. 

Control Techniques: 

The uncontrolled NOx emission factors for line hauling and switching locomotives are 

estimated at 9.5 g/bhp-hr and 14.0 g/bhp-hr respectively. The following control 

technique is available to reduce NOx emissions below the current emission level: 

1. Repower of locomotives with cleaner engines that meet Tier 2 or Tier 3 emissions 

standards. 

Emission Inventory and Potential Emission Reductions with no Constraints: 

The projected inventory for locomotives, assuming no incentives are provided, is 

expected to be nearly constant through 2023. Assuming no financial, technological, or 

logistical constraints existed, all 198 locomotives could be immediately retrofitted with 

Tier 2 engines at an estimated cost of $148,500,000. This strategy would result in a 

reduction of approximately 9.7 tons of NOx per day by 2008. 

Another no constraints scenario is to retrofit of all locomotives with Tier 3 engines in 

2012, when the engines are expected to be available. At a cost of $297,700,000 and 

again assuming that no financial, technological, or logistical constraints exist, the 

projected inventory with no incentives for 2012 and beyond can potentially be reduced 

by a total of 15.8 tons of NOx per day. 
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Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 24.8 24.8 24.8 24.8 24.8 

No Constraints Inventory 15.1 9.0 9.0 9.0 9.0 

No Constraints Reductions 9.7 15.8 15.8 15.8 15.8 

Possible Scenarios: 

Scenario 1: Repower all Locomotives in the District with Tier II engines by 2012 

• All 198 locomotive engines could conceivably be repowered with Tier II 

engines by 2012 

• At an estimated $750,000 per repower, the total project cost for this Scenario 

is an estimated $148,500,000 

• This scenario reduces NOx emissions by 9.7 tons/day 

This scenario results in maximum emission reductions in 2012; however, no further 

emission reductions occur after 2012. Furthermore, the level of funding required to 

repower all of the locomotives is approximately $148,500,000. 

Scenario 2: Repower all locomotives in the District with Tier III engines by 2015 

• All 198 locomotives could conceivably be replaced with Tier III engines by 2015 

• At an estimated cost of $1.5 million per locomotive, the total cost to repower all 198 

locomotives is estimated to be $297,700,000 

• This scenario reduces NOx emissions by approximately 15.8 tons/day by 2015 

To accomplish this scenario, 65 locomotives must be repowered each year at a total 

annual cost of approximately 100 million per year. 

Scenario 3: Repower 75 percent of all switch locomotives with Tier II engines by 2012, 

then repower 50 percent of all switch locomotives with Tier III engines by 2015 

• Under this scenario, at least 19 switch engines are first repowered to meet Tier II 

standards, and then later repowered by 2015 to meet Tier III standards 

• The total cost of this scenario is estimated to be $77,437,500, with $38,187,500 

required by 2012 and another $39,250,000 required between 2012 and 2015 

• This scenario reduces NOx emissions by approximately 0.7 tons/day in 2012 and 

1.5 tons/day in 2015 and later years 

Scenario 4: Repower 25% of line haul locomotives by 2012, repower 50% of line-haul 

locomotives with Tier III engines by 2015 

 
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The total cost of this scenario is estimated to be $130,312,500, with $26,025,000 

required by 2012, and an additional $104,287,500 required between 2012 and 2015. 

This scenario reduces NOx emissions by approximately 4.5 tons/day in 2012 and 9.9 

tons/day in 2015 and later inventory years 

Since some line haul locomotives operate both within and outside of the San Joaquin 

Valley Air Basin, co-operation with ARB and other air districts may be necessary to 

accomplish this scenario. However, there are many short haul locomotives that operate 

solely within the District that could first be targeted by the incentive program. 

Recommendation: 

Scenarios 1 and 2 require significant levels of annual funds to accomplish. Both 

Scenarios 3 and 4 require lower annual funds than Scenarios 1 and 2. Furthermore, 

Scenarios 3 and 4 both result in significant annual emission reductions by 2015. 

Therefore, staff recommends simultaneously pursuing both Scenarios 3 and 4. 

Recommended Strategy (Scenario #3)

Total Project Cost $77,437,500

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $38,718,750

Total Incentive Funds Needed (Cost) $38,718,750

Existing Available Funding $20,000,000

New Funding Required $18,718,750

Recommended Strategy (Scenario #4)

Total Project Cost $130,312,500

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $65,156,250

Total Incentive Funds Needed (Cost) $65,156,250

Existing Available Funding $28,000,000

New Funding Required $37,156,250
- NOT FOR INCLUSION IN SIP - 

San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Diesel-Fired Agricultural Tractors (M-IND-1) 

Source Category: 

This source category includes diesel-fired agricultural tractors. The emissions from 

diesel-fired agricultural tractors account for approximately 95% of the total NOx 

emissions from the “Farm Equipment” source category. 

Assuming an incentive program is not commenced by 2023 for this category of 

equipment, ARB estimates the following equipment populations for 2008, 2012, 2017, 

2020, and 2023. The equipment is categorized by an emissions Tier level, with Tier 0 

corresponding to an uncontrolled, high polluting tractor and Tier 4 corresponding to the 

least polluting tractor. 

Population by Tier Level at Critical Years 

Population Tier Rating 2008 2012 2017 2020 2023 

Uncontrolled 18,789 8,763 2,847 1,587 589 

Tier 1 21,138 16,068 6,795 3,557 2,049 

Tier 2 23,229 15,469 11,852 7,629 3,657 

Tier 3 11,318 28,925 23,393 20,793 17,432 

Tier 4 0 4,322 27,503 38,127 47,290 

Total 74,474 73,547 72,390 71,693 71,017 

As shown in the table above, many of the higher polluting Tier 0, Tier 1 and Tier 2 

tractors are eventually replaced by lower polluting Tier 3 or Tier 4 tractors. The 

replacement of older Tier 0, Tier 1, and Tier 2 tractors is driven by regulations and by 

natural turnover, where older equipment is taken out of service and replaced with new 

equipment. 

Upcoming Regulations: 

Tier 1-3 Standards: The first federal standards (Tier 1) for new non-road (or off-road) 

diesel engines were adopted in 1994 for engines over 37 kW (50 hp), to be phased-in 

from 1996 to 2000. In 1996, a Statement of Principles (SOP) pertaining to non-road 

diesel engines was signed between EPA, ARB and engine makers (including 

Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, 

Navistar, New Holland, Wis-Con, and Yanmar). On August 27, 1998, the EPA signed 

the final rule reflecting the provisions of the SOP. The 1998 regulation introduced Tier 1 

standards for equipment under 37 kW (50 hp) and increasingly more stringent Tier 2 

and Tier 3 standards for all equipment with phase-in schedules from 2000 to 2008. The 

Tier 1-3 standards are met through advanced engine design, with no or only limited use 

of exhaust gas aftertreatment (oxidation catalysts). Tier 3 standards for NOx+HC are 

similar in stringency to the 2004 standards for highway engines, however Tier 3 

standards for PM were never adopted.
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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Tier 4 Standards: On May 11, 2004, the EPA signed the final rule introducing Tier 4 

emission standards, which are to be phased-in over the period of 2008-2015. The Tier 

4 standards require that emissions of PM and NOx be further reduced by about 90%. 

Such emission reductions can be achieved through the use of control technologies, 

including advanced exhaust gas aftertreatment, similar to those required by the 2007-

2010 standards for highway engines. 

Control Techniques: 

Various options for controlling emissions are listed below: 

1. Accelerated Fleet Turnover by replacing of older tractors with new tractors, which 

utilize the cleanest technology available. Tier 3 tractors will be phased into 

production between 2006 and 2008. Tier 4 tractors are currently scheduled to be 

phased into production between 2008 and 2015, with most tractor manufacturers 

beginning production between 2011 and 2015. 

2. Retrofitting of tractors through the installation of a retrofit device that reduce one or 

more pollutants. 

3. Engine Repower by replacing the tractor engines with new or newer engines 

Emission Inventory and Possible Emission Reductions with no Constraints:

Assuming there are no constraints, such as availability, cost, and participation, the 

following emission reductions could be achieved. The following table assumes that all 

tractors (100%) are replaced as soon as the newest technology becomes available. 

In other words, 100% of all tractors (54,701 tractors) that currently do not meet Tier 3 or 

Tier 4 control standards would be replaced with a Tier 3 or 4 tractor in year 2008, and in 

years 2011, 2012, and 2013 the remaining non Tier 4 tractors would be replaced with 

Tier 4 tractors (19,611, 19,238, and 5,343 tractors, respectively). The total cost to 

replace these 98,893 tractors is approximately $9.7 billion dollars. 

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 52.67 42.43 28.83 22.19 16.95 

No Constraints Inventory 26.85 18.45 14.09 12.56 11.60 

No Constraints Reductions 25.82 23.97 14.74 9.64 5.35 

Possible Strategies:

An optimal scenario would have to identify a grouping of vehicles that can achieve 

meaningful emission reductions early (before 2012) while leaving sufficient resources 
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for eventual replacement of vehicles with the cleanest control technology, which will be 

available in 2011 through 2013. The following are the key emissions in key years for 

the Tier groups. 

Emission Inventory Table

2008 2010 2012 2020 

# of 

Vehicles 

Emissions 

(tons/day) 

# of 

Vehicles

Emissions 

(tons/day) 

# of 

Vehicles

Emissions 

(tons/day) 

# of 

Vehicles

Emissions 

(tons/day) 

Tier 0 18,789 20.39 14,087 14.79 8,763 9.25 1,587 1.54 

Tier 1 21,138 17.22 18,584 16.50 16,068 14.12 3,557 3.32 

Tier 2 23,229 10.92 18,394 10.33 15,469 9.82 7,629 4.75 

Tier 3 11,318 4.15 22,948 6.70 28,925 7.81 20,793 6.31 

Tier 4 0 0.00 0 0.00 4,322 1.42 38,127 6.27 

Scenario 1: Replacement of 100% of eligible tractors as soon as the newest technology 

becomes available 

Replacement of all tractors as soon as the newest technology becomes available is not 

feasible when considering manufacturing limitations (54,701 tractors alone in 2008). 

Therefore, more reasonable scenarios will be considered. 

Scenario 2: Replacement of all eligible tractors beginning in 2008 with a 10% per year 

penetration 

According to the inventory data, the highest number of tractors to be replaced would 

take place in 2008, where 5,470 tractors would be replaced with Tier 3 or 4 tractors and 

the number of tractors to be replaced would gradually decrease with each year. 

The table below shows the effect this alternate type of incentive program would have on 

the expected NOx emissions in the 2008, 2012, 2017, 2020, and 2023 inventory years. 

Tons NOx Per Day – Summer Season 

Scenario 2 2008 2012 2017 2020 2023 

Baseline 52.67 42.43 28.83 22.19 16.95 

Adjusted Baseline 

All Eligible Tractors Replaced 50.08 33.84 19.58 15.16 11.96 

Reductions from Baseline 2.59 8.59 9.25 7.03 4.99 

As shown above, this scenario results in significant reduction of emissions in 2012, 

2017, 2020, and 2023 inventory years. The estimated total cost involved with this 

incentive option is highlighted in the table below. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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Scenario 2 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

All Eligible Tractors 

Replaced $4,220,875,056 $117,873.78 

Advantages: 

• Early reductions in emissions, beginning in 2008. 

• Significant NOx emission reductions are achieved in 2012, 2017, 2020, 

and 2023. 

 

Disadvantages: 

• Costly ($4.2 billion) option to implement. 

• Not a cost-effective ($/ton) option. 

Scenario 3: Replacement of only Tier 0 and Tier 1 Tractors beginning in 2008 with a 

10% per year penetration 

According to inventory data, at a 10% penetration rate for Tier 0 and Tier 1 tractors, the 

highest number of tractors to be replaced would take place in 2008, where 4,791 Tier 0 

and 1 tractors would be replaced with Tier 3 and 4 tractors and the number of tractors to 

be replaced gradually decreases with each year. 

The table below shows the affect this type of incentive program would have on the 

expected NOx emissions in the 2008, 2012, 2017, 2020, and 2023 inventory years. 

Tons NOx Per Day – Summer Season 

Scenario 3 2008 2012 2017 2020 2023 

Baseline 52.67 42.43 28.83 22.19 16.95 

Adjusted Baseline 

Tier 0 and Tier 1 Replaced 50.46 36.14 25.19 20.15 15.81 

Reductions from Baseline 2.21 6.29 3.64 2.04 1.14 

As shown above, this scenario results in significant reductions in emissions in 2012, 

however only slight reductions are achieved in the 2020 and 2023 inventory years. The 

estimated total cost involved with this incentive option is highlighted in the table below. 

Scenario 3 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Tier 0 and Tier 1 Replaced $1,595,935,513 $64,639.84 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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Advantages: 

• Early reductions in emissions, beginning in 2008. 

• Significant NOx emission reductions are achieved in 2012. 

• Considerable effect on 2017, 2020, and 2023 NOx emission inventories. 

Disadvantages: 

• Costly ($1.6 billion) option to implement. 

• Not a cost-effective ($/ton) option. 

Scenario 4: Replacement of only Tier 1 Tractors beginning in 2008 with a 10% per year 

penetration 

According to inventory data, at a 10% penetration rate for Tier 1 tractors, the highest 

number of tractors to be replaced would take place in 2008, where 2,114 Tier 1 tractors 

would be replaced with Tier 3 or 4 tractors and the number of tractors to be replaced 

gradually decreases with each year. 

The table below shows the effect this type of incentive program would have on the 

expected NOx emissions in the 2008, 2012, 2017, 2020, and 2023 inventory years. 

Tons NOx Per Day – Summer Season 

Scenario 4 2008 2012 2017 2020 2023 

Baseline 52.67 42.43 28.83 22.19 16.95 

Adjusted Baseline 

Tier 1 Replaced 51.78 38.65 26.62 20.46 15.73 

Reductions from Baseline 0.89 3.78 2.21 1.73 1.22 

As shown above, this scenario results in only slight reductions in the 2012, 2017, 2020, 

and 2023 inventory years. The estimated total cost involved with this incentive option is 

highlighted in the table below. 

Scenario 4 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Tier 1 Replaced $1,014,021,525 $72,881.79 

Advantages: 

• Early reductions in emissions, beginning in 2008. 

• Decent effect on 2012, 2017, 2020 and 2023 NOx emission inventories. 

Disadvantages: 
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• Costly ($1.0 billion) option to implement. 

• Not a cost-effective ($/ton) option. 

• Minimal effect on 2008 NOx emission inventory. 

Scenario 5: Replacement of only Tier 0 Tractors beginning in 2008 with a 10% per year 

penetration 

According to inventory data, at a 10% penetration rate for Tier 0 tractors, the highest 

number of tractors to be replaced would take place in 2008, where 1,879 Tier 0 tractors 

would be replaced with Tier 3 or 4 tractors and the number of tractors to be replaced 

gradually decreases with each year. 

The table below shows the effect this type of incentive program would have on the 

expected NOx emissions in the 2008, 2012, 2015, 2017, 2020, and 2023 inventory 

years. 

Tons NOx Per Day – Summer Season 

Scenario 5 2008 2012 2015 2017 2020 2023 

Baseline 52.67 42.43 33.75 28.83 22.19 16.95 

Adjusted Baseline 

Tier 0 Replaced 51.34 39.51 30.87 26.67 21.07 16.44 

Reductions from Baseline 1.33 2.92 2.88 2.16 1.12 0.51 

As shown above, this scenario results in only slight reductions in the 2012, 2015, 2017, 

2020, and 2023 inventory years. The estimated total cost involved with this incentive 

option is highlighted in the table below. 

Scenario 5 Total Estimated 

Cost 

Cost Effectiveness 

($/ton of NOx Reduced) 

Tier 0 Replaced $581,913,987 $49,169.61 

Advantages: 

• Early reductions in emissions, beginning in 2008. 

• Most cost-effective option 

• Decent effect on 2008, 2012, 2017, 2020 and 2023 NOx emission 

inventories. 
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Recommendation: 

Scenario 5 is recommended because it addresses the highest polluting tractors and 

replaces them with the cleanest technology available. It also provides similar reductions 

in emissions during the 2017, 2020 and 2023 inventory years at a fraction of the overall 

total costs when compared to the other scenarios. 

Recommended Strategy

Total Project Cost $581,913,987

Grant Recipient Match (Percent) 30%

Grant Recipient Match (Cost) $174,574,196

Total Incentive Funds Needed (Cost) $407,339,791

Existing Available Funding $2,000,000

New Funding Required $405,339,791
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School Boilers (S-COM-2) 

Source Category: 

This source category includes approximately 380 boilers with 2-5 MMBtu/hr output 

located at schools kindergarten through 12th grade. 

Upcoming Regulations: 

District Rule 4307 sets NOx limits at 30 ppmv effective in 2009. This is approximately 

70% NOx control from uncontrolled levels. Units operated at schools kindergarten 

through 12th grade are exempt. 

Control Techniques: 

There are several options for controlling emissions. 

1. Replace with new Low NOx (30ppm) boiler 

2. Retrofit with Low NOx (30 ppm) burner 

1. Replace with Ultra Low NOx (15 ppm) boiler 

Emission Inventory and Possible Emission Reductions with no Constraints: 

Maximum reductions would be achieved by replacing the approximately 380 school 

boilers with Ultra Low NOx (15ppm) units. Assuming 100% District funding, the total 

cost of this control is approximately $57,000,000. 

Potential NOx Emission Reductions Assuming No Financial, 

Technological, or Logistical Constraints 

(Tons Per Day)

 2008 2012 2017 2020 2023 

Projected Inventory with no Incentives 0.80 0.80 0.80 0.80 0.80 

No Constraints Inventory 0.10 0.10 0.10 0.10 0.10 

No Constraints Reductions 0.70 0.70 0.70 0.70 0.70 

Possible Strategies: 

Scenario 1: Replace all units in the District with Low NOx (30 ppm) boilers. 

• NOx reduction – 0.51 tons per day 

• Total cost - $24,553,700 

Scenario 2: Retrofit all units in the District with Low NOx (30 ppm) burners. 

• NOx reduction – 0.51 tons per day 

• Total cost - $17,773,500 
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Scenario 3: Replace all units in the District with Ultra Low NOx (15ppm) boilers. 

• NOx reduction – 0.70 tons per day 

• Total cost - $57,000,000 

Recommendations: 

Staff recommends Scenario 1, as this scenario is the most realistic and cost effective. 

Scenario 2 is not recommended because grant history indicates that participation is 

higher for programs that offer full replacement as opposed to retrofit. Scenario 3 is not 

recommended at this time because the Ultra Low NOx boilers are costly and not as 

readily available as the Low NOx boilers. Scenario 3 may be considered in the future if 

the units become more common and less costly. 

Recommended Strategy

Total Project Cost $24,553,700

Grant Recipient Match (Percent) 50%

Grant Recipient Match (Cost) $12,266,850

Total Incentive Funds Needed (Cost) $12,266,850

Existing Available Funding $0

New Funding Required $12,266,850
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7.6.2 Recommended Funding Levels for Incentive Control Measures 

The following table identifies the recommended incentive program strategies along with 

the associated funding amounts. 

Incentive Control Measures Recommended For Funding 

Incentive Control 

Measure Total Project Cost Number of Units 

Grant 

Recipient 

Match 

(percent) 

Total Incentive 

Funds Needed 

(Cost) 

Existing Local 

Funding 

New Funding 

Required 

Passenger and 

Medium Duty Vehicles 

Replace 1% to 4% 

each year between 

2008 and 2020 

$176,900,000 35,380 30% $123,830,000 $26,911,818 $96,918,182 

Forklifts 

Replace 90% of 

forklifts with sparkignited forklifts and 

10% of forklifts with 

electric forklifts 

between 2008 and 

2010 

$23,536,240 800 50% $11,768,120 $6,500,000 $5,268,120 

School Boilers 

Replace all units in the 

District with low NOx 

(30 ppm) boilers 

beginning in 2015 

$24,553,700 380 50% $12,276,850 $1,800,000 $10,476,850 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

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Incentive Control Measures Recommended For Funding 

Ag Tractor 

Replace Tier 0 

Tractors beginning in 

2008 with a 10% 

penetration per year 

$581,913,987 6,997 30% $407,339,791 $2,000,000 $405,339,791 

CI Ag Engines 

Tier 0 replacement 

with Tier 3 between 

2007 and 2008 

$50,746,820 1,915 30% $35,522,774 $35,522,774 $0 

CI Ag Engines 

Replace Tier 1 and 

Tier 2 engines with 

Tier 4 between 2012 

and 2014 

$92,794,960 2,582 30% $64,956,472 $32,000,000 $32,956,472 

CI Ag Engines 

Electrify 50% of Tier 3 

engines between 2020 

and 2023 

$76,366,539 980 30% $53,456,577 $35,000,000 $18,456,577 

CI Ag Engines 

Implement pump 

efficiency for 10% of 

pumps between 2008 

and 2017 

$130,129,171 4,542 75% $32,532,293 $0 $32,532,293 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

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Incentive Control Measures Recommended For Funding 

Diesel Trucks 

Replace 75% of 1991-

1993 model year 

trucks between 2008 

and 2009; Replace 

10% of pre-2007 

trucks between 2010 

and 2023 

$4,174,781,627 28,089 50% $2,087,390,814 $328,338,180 $1,759,052,634

Construction 

Equipment 

Replacement of 10 

compactors, 10 

crawlers dozers, 10 

earth movers, 10 

motor graders, and 10 

scrapers between 

2008 and 2023 

$66,108,900 50 20% $52,887,120 $25,000,000 $27,887,120 

Locomotives 

Repower 40 

locomotives with Tier 

2 engines by 2012 and 

repower 30 switch 

locomotives by 2020 

$77,437,500 59 50% $38,718,750 $20,000,000 $18,718,750 

Locomotives 

Repower 35 line haul 

locomotives 2012, 

then repower 70 short 

line-haulers with Tier 3 

engines by 2020 

$130,312,500 105 50% $65,156,250 $28,000,000 $37,156,250 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

2007 Ozone Plan 

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Incentive Control Measures Recommended For Funding 

Off-road portable 

engines 

Replace all Tier 0 and 

Tier 1 replace with 

Tier 3 between 2008 

and 2012 

$62,807,157 4,299 50% $31,403,579 $12,000,000 $19,403,579 

Off-road portable 

engines 

Replace all Tier 2 with 

Tier 3 between 2012 

and 2016 

$56,988,150 1,800 50% $28,494,075 $2,000,000 $26,494,075 

Off-road portable 

engines 

Replace all Tier 3 with 

Tier 4 engines 

between 2016 and 

2020 

$59,097,000 1,932 50% $29,548,500 $2,000,000 $27,548,500 

Totals $5,646,019,705 96,596 $2,978,363,782 $557,072,772 $2,421,291,010
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

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The following table identifies the necessary funding levels by year to implement the 

recommended incentive control measures. 

Schedule for Funding by Year 

Timeline For Funding 

Year 

New Funding 

Required Existing Funding 

2007 and 2008 $137,000,000 $80,000,000 

2009 $137,700,000 $40,000,000 

2010 $137,700,000 $40,000,000 

2011 $137,700,000 $40,000,000 

2012 $168,400,000 $40,000,000 

2013 $161,800,000 $40,000,000 

2014 $161,800,000 $40,000,000 

2015 $141,400,000 $40,000,000 

2016 $161,800,000 $24,700,000 

2017 $156,500,000 $24,700,000 

2018 $153,200,000 $24,700,000 

2019 $153,200,000 $24,700,000 

2020 $167,200,000 $24,700,000 

2021 $149,400,000 $24,700,000 

2022 $149,400,000 $24,700,000 

2023 $149,400,000 $24,700,000 

Total $2,423,600,000 $557,600,000 

Formal SIP revisions will be considered upon the receipt of major blocks of funding. 

7.6.3 Incentive Measures for Possible Future Consideration 

The following possible incentive measure categories are not candidates for incentive 

funding at this time, but are being recommended for further analysis and study for future 

consideration: 

• Large Spark-Ignited Agricultural Engines 

Replace older agricultural irrigation pump engines with new spark-ignited engines. 

• Inland Port Infrastructure 

Explore options to provide linkages between ports and other modes of 

transportations, such as by train for the delivery of goods. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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• Short Sea Shipping 

Reduce heavy-duty truck and locomotive vehicle miles traveled through the District 

by transporting goods by sea between northern and southern California. 

• Heavy-Duty Gasoline Trucks 

Reduce emissions by replacing older heavy-duty gasoline trucks with new trucks. 

• Buses (other than transit and school buses) 

Replace older buses with new buses. 

• Motorcycles 

Reduce emissions from older on-road motorcycles. 

• Residential Water Heaters 

Replace existing water heaters with electric or tankless models. 

• Open Burning 

Measures to reduce the on-field burning of agricultural waste. 

• Composting Green Waste 

Reduce emissions by installing an enclosed aerated static pile vented to a biofilter at 

all green waste facilities. 

• Agricultural Above Ground Gasoline Storage Tanks 

Reduce evaporative emissions of VOC from above ground storage tanks by 

increasing heat reflection and installing a pressure vacuum vent valve on the tanks. 

7.7 LEGISLATIVE ACTION PLAN FOR SECURING PROPOSED FUNDING 

At the federal level, the District is seeking to receive enhanced funding through the 

establishment of a new designation as an Air Quality Empowerment Zone. The new 

designation will give the Valley priority for funding through existing programs as well as 

acting as an umbrella for new funding sources. Specifically, we are requesting that the 

San Joaquin Valley be given priority in the DERA and EQIP funding allocations, and 

that these programs be funded at higher levels than they have historically received. 

Additionally, the District is seeking new federal appropriations as well as tax incentives 

for the purchase of cleaner lower-emitting equipment. 

At the state level, the District is advocating for both near term funding through the 

Proposition 1B bond funds, and longer-term funding through the establishment of an Air 

Quality Enterprise Zone that would serve as an umbrella for additional state funding and 

tax-incentives for new clean equipment purchases. 
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San Joaquin Valley Unified Air Pollution Control District April 30, 2007 

Chapter 7: Action Plan for Reducing Emissions with Incentive Funds 

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The passage of Proposition 1B provides $1 billion for emission reductions from activities 

related to the movement of freight through California’s trade corridors. The San Joaquin 

Valley is the major north/south corridor for movement of freight through the State of 

California. Additionally, there is a significant trade corridor of agricultural commodities 

from the San Joaquin Valley to California ports. Over 28% of the state’s truck traffic 

occurs in the District and nearly 80% of the San Joaquin Valley’s smog and particulate 

causing emissions come from mobile sources. The District is seeking 25%, or $250 

million, of the Proposition 1B emission reduction funds to mitigate the impact from 

increased freight movement through the region. 

Additionally, Proposition 1B contains $200 million to fund the replacement of Pre-1987 

school buses, and the retrofit of new school buses. The District has a disproportionate 

share of older high emitting school buses with over 30% of the school buses in the 

District being 1987 or older. Pre-1987 buses expose students to high levels of 

carcinogens from diesel exhaust and add to the District’s ambient air quality pollution. 

Current funding levels are inadequate to allow school districts to replace these buses. 

The District is seeking to secure significant Proposition 1B school bus funding to replace 

and retrofit higher emitting school buses. 

The funding requests that are included in this plan are consistent with the 

recommendations that have been approved by the Air Quality Work Group of the 

Governor’s California Partnership for the San Joaquin Valley. As such, they should be 

endorsed by the State Government. Additionally, District staff and stakeholders have 

had a number of meetings with the San Joaquin Valley congressional delegation 

(Congressman Jim Costa, Dennis Cardoza, George Radanovich, and Devin Nunes) and 

Senators Feinstein and Boxer to discuss the federal funding strategy. There is 

agreement amongst our federal representatives that there is a need for $100 million per 

year in federal incentive funding, and a willingness to work together to obtain additional 

resources for air quality projects in the San Joaquin Valley.